Day 003 - 30 Jun 94 - Page 47


     
     1   Q.   Were those your instructions to the solicitors?
              A.  Those were my instructions, yes, Sir.
     2
         Q.   Had that invitation been accepted would that have been the
     3        end of the matter?
              A.  That would have been the end of it.
     4
         Q.   Yesterday in court, you were not here, the defendants
     5        accused you of bringing this action in order to censor
              freedom of speech, in order to intimidate and bully your
     6        critics into silence; they compared you, or your use of
              legal proceedings, with that of the late Mr. Robert
     7        Maxwell.  Can you please give me or his Lordship your
              reaction to those suggestions?
     8        A.  I find them very offensive.
 
     9   Q.   Have you brought these proceedings in order to silence
              publication of the truth?
    10        A.  These proceedings have nothing to do with free speech,
              or silencing the truth; quite the opposite; it is here to
    11        establish the truth.  Once and for all.
 
    12   Q.   Are you trying to silence fair criticism of your company?
              A.  I am not trying to silence fair criticism of
    13        McDonald's.
 
    14   Q.   Have you, as the defendants repeatedly assert both inside
              and outside this court, caused your company to hide or
    15        cover up large numbers of documents which would prove the
              truth of these allegations?
    16        A.  There is nothing hidden, nothing has been covered up;
              everything has been available.
    17
         Q.   Does your company keep large numbers of documents for long
    18        periods of time?
              A.  We keep some documents but McDonald's is not a paper
    19        crushing organisation.  We tend to use electronics.  We
              tend to communicate orally.  Someone asked me that
    20        question some years ago.  I answered it saying, "We are
              not the civil service; we do not document, write down
    21        meeting notes about everything we do or talk about".  We
              periodically purge files, throw away that which is no
    22        longer relevant, grind them, destroy keep, keep what is
              here now and necessary to run the business and go
    23        forward.  That is all.
 
    24   Q.   Is there a sort of system or policy for documents in
              McDonald's or is it left, largely speaking, to the
    25        individual or what he does with his own documents?
              A.  It is left pretty much to the individual, the 
    26        operations arm who are charged with monitoring a licensee 
              do what has to be done with that person.  We do not try to 
    27        give everyone one set of blanket rules to operate by,
              "Save this, keep that, throw away the following".  That
    28        is not the way the culture runs.
 
    29   Q.   I suppose if there is a legal case still in being either
              for or against the company, then the documents will be
    30        kept with the solicitors?
              A.  If there is something required in a legal action they

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