Day 008 - 07 Jul 94 - Page 59


     
     1
         MR. JUSTICE BELL:  There is a date in the very bottom
     2        right-hand corner.
 
     3   MR. MORRIS:  19.
 
     4   MR. RAMPTON:  Does it say?
              A.  6.9.89.
     5
         Q.   I am not going to ask you about any part of the first two
     6        pages of this.  One can see the word Tasmania at the top
              of the left-hand page.  Page 3, Mr. Langert, internal page
     7        3, file page 670.  "Question" -- can I ask you this, do
              you recognise from its character what was the purpose of
     8        this document, who is going to read this?
              A.  This had to be prepared either -- this was prepared
     9        for customer enquiries.
 
    10   MR. JUSTICE BELL:  What is written in the top left-hand
              corner?  It is cut off in my copy.
    11
         MISS STEEL:  "Sent by Hamburger Action Group as Tasmania".
    12        A.  This document would have been prepared for customer
              enquiries, to answer customer enquiries, to give them
    13        information about their activities.
 
    14   MR. RAMPTON:  Either they would get it or the staff might use
              the information?
    15        A.  Either they would write into the corporation or call
              in, send in some information or the stores might have it.
    16
         Q.   The information contained in this document is intended for
    17        public consumption?
              A.  Yes.
    18
         Q.   The third page:  Question: "What about using recycled
    19        paper?"  This is September 1989, assuming the Australians
              use the British method of dating things rather than the
    20        American.  "What about using recycled paper?"  Answer:
              McDonald's is already one of the largest users of recycled
    21        paper board in the Australian restaurant industry".
 
    22        Pause there, please, Mr. Langert.  Suppose one substitutes
              for the word "Australian" for the words "United States":
    23         "McDonald's is already one of the largest users of
              recycled paper board in the United States restaurant
    24        industry",  would that have been a true or a false
              statement in September 1989?
    25        A.  True.
  
    26   Q.   Could you in the United States actually have gone a step 
              further than saying it was one of the largest users in the 
    27        restaurant industry in the United States?
              A.  Yes, we could even quantify that, if you like.
    28
         Q.   Could you have said it was the largest or the second
    29        largest or the third largest?
              A.  In our?
    30
         Q.   In September 1989?

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