Day 008 - 07 Jul 94 - Page 51


     
     1        also changing our tray liners to recycled paper stock.
 
     2   Q.   Can I ask you this, because I do not want to leave the
              thing in the air:  When you get back to the United States,
     3        can you and Mr. Kouchoukos have a discussion about this
              and come up with an agreed solution as to what is the
     4        correct percentage for these different years?
 
     5        If he has used only 107 recycled items, even for 1991 his
              figure of 51 per cent is going to be far too low.  If he
     6        has used only items which are 100 per cent recycled, his
              figure of 51 per cent for 1991 ----
     7        A.  You might conclude that but ----
 
     8   MR. JUSTICE BELL:  He may not have followed the same course?
              A.  He may not have.  I believe what he did since of all
     9        our recycle packaging that he would have quantified is
              made with 100 per cent, I think it is probably -----
    10
         Q.   It would be extraordinary pulp trays were half the
    11        consumer packaging in 1991, would it not?
              A.  Yes, we will do that.
    12
         MR. RAMPTON:  In 1991, 1992 were there any other items besides
    13        pulp trays that were 100 per cent recycled?
              A.  We made progressive steps, adding more and more
    14        things.  Yes, there were more items that came on board.
 
    15   Q.   I do not want to tax you with it now.  I do not want to
              suggest we have reached a conclusion about this now.  I do
    16        not want to go into it any further at this stage.  What
              I would like you to do, if it is acceptable to you and to
    17        his Lordship, is to go home and next week, as soon as you
              can, talk to Mr. Kouchoukos about it and see if you can
    18        arrive at an agreed conclusion about these figures and
              transmit them to us for use in this court explaining,
    19        where necessary, how the calculations have been arrived
              at.  Will you do that for us?
    20        A.  Yes.
 
    21   MR. MORRIS:  Can I ask on the subject, if there is any area of
              confusion, it would be most useful to get disclosure of
    22        documents rather than a completely new document which show
              the recycle content and the total amount of volume, etc.,
    23        etc., which would indicate the truth of the picture at the
              time.
    24
         MR. JUSTICE BELL:  What I suggest is that we start with what
    25        Mr. Rampton has asked for.  If, when one looks at that,
              you are not content with any of the component figures, 
    26        then we will decide whether it is only right that there 
              should be further disclosure to see whether they can be 
    27        supported or not.
 
    28        But let us start with the first sheet.  I do not want to
              be suggesting that there be what may be extremely
    29        extensive discovery before we know whether it is necessary
              or helpful or not.
    30
         MR. MORRIS:  It would not have to be extensive discovery.

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