Day 164 - 26 Sep 95 - Page 28
1 be a composite document or not. All they have now and have
2 had for the purposes of this case is the executive
3 summary.
4
5 I took with me when I went to Chicago Mr. Marcheid's
6 statement and the executive summary. I asked whether
7 Towers and Perrin still had the original study and final
8 report, call it what you like. The answer was that they
9 did not and that they had destroyed it for the reasons
10 which I have given as soon as they delivered the final
11 report and study to McDonald's. As for the idea that every
12 research organisation retains all that it has ever done,
13 one only has to contemplate what one does with one's old
14 opinions to realise -----
15
16 MR. JUSTICE BELL: Let me make sure I understand it, because my
17 reading of Mr. Marcheid's letter is that the report which
18 was produced for McDonald's by this firm included an
19 executive summary. The executive summary is not a separate
20 report. It is some pages of the report. McDonald's have
21 that part of the report, copies of which are in our
22 bundles, but they do not have the rest of the full report.
23 Towers and Perrin, it has been said in open court, do not
24 have anything.
25
26 MR. RAMPTON: They do not have anything.
27
28 MR. JUSTICE BELL: You see, if you pursued this to its logical
29 and legal conclusion, the only issue would be whether
30 I ordered that an affidavit be sworn by someone who would
31 set out the source of their information and belief, because
32 it would, presumably, be a solicitor in this country who
33 would say whom they had spoken to. The reality is it would
34 only duplicate what leading counsel has said in open court,
35 so it amounts to the same thing and you can base any
36 comment which you wish to make in due course on that.
37 Yes?
38
39 MR. MORRIS: I wanted to leave the Bath documents until after
40 lunch because I have not got the statements with me, not
41 the Sean Richard statement anyway.
42
43 In the statement of Chantal Villeneuve-Gallez, our witness
44 from France, from the Lyons area, who people recall is a
45 union rep or a union organiser in the McDonald's store in
46 Lyons -- one of them. She refers to -- I have not got it
47 here, it is on the last page of her statement; I am doing
48 it from memory -- 50 employees made witness statements to
49 the police as part of the judicial investigation of
50 McDonald's and claims about sabotaging of union elections.
51 We believe those statements -----
52
53 MR. RAMPTON: My Lord, once again, I fear I do have to
54 interrupt. It is not Chantal Villeneuve-Gallez; it is
55 Hassen Lamti.
56
57 MR. MORRIS: I am sorry about that.
58
59 MR. RAMPTON: What Mr. Morris has said about is it not
60 accurate. It is best your Lordship looks at it. It is
