Day 009 - 08 Jul 94 - Page 62


     
     1   MR. MORRIS:  I think it appeared on tray liners explaining
              about the cartons that had HCFCs.  Is that your
     2        understanding of it?
              A.  I am sure that what we did as part of our educational
     3        commitment is to communicate our changes with an important
              issue.  We want to communicate it to our customers.  We
     4        would have used a tray liner to communicate that.  We
              would have used a "Did you know?" pamphlet.   We would
     5        have put it in any other type of information that we could
              possibly do so in order to communicate that change.
     6
         Q.   Is it not a fact that it was a place mat headlined "Facts
     7        about foam" and stated:  "McDonald's foam packaging is
              manufactured without" underlined "the use of
     8        Chloroflorocarbons which are thought to be harmful to the
              ozone layer".  Do you recall that?
     9        A.  Well, I am sure that is an accurate statement, what
              you have just said, correct.  I have to see the exact tray
    10        liner.
 
    11   Q.   But that would be, in your opinion, an accurate
              description of what happened?
    12        A.  Yes.  If you would like me to relook at it, I can
              verify it, if you like.
    13
         Q.   I have not got the original document.
    14        A.  Could I just take a look at that for a second?
 
    15   MR. JUSTICE BELL:  He says he does not have the original.
 
    16   MR. MORRIS:  I have an article.
              A.  I did not quite get the first half of his comments.
    17
         MR. JUSTICE BELL:  What he asked you, after you gave had given
    18        your original answer, was would that be, in your view, an
              accurate description?
    19        A.  He was quoting something.  I did not get the first
              half of that quote exactly.
    20
         MR. MORRIS:  Let me just quote you.  It is an article in the
    21        Washington Post, December 10th 1989.  I believe it is part
              of our documents.
    22
         MR. JUSTICE BELL:  Just put the quote and then see.
    23
         MR. MORRIS:  "The place mat in question" which is referring to
    24        McDonald's "contains a large amount of text McDonald's
              with smiling Big Mac containers", in brackets, "(clam
    25        shells they are called in the trade), a section boldly
              headlined:  'Facts about foam' declares that:  'McDonald's 
    26        foam packaging is manufactured without'", in italics, 
               "'the use of chloroflorocarbons (CFCs) which are thought 
    27        to be harmful to the ozone layer'"?
              A.  That is a totally accurate statement.
    28
         Q.   Yes.  Are you aware of Michael Oppenheimer, a senior
    29        scientist with the Environmental Defence Fund?
              A.  I am aware of some of his work.  He has published
    30        articles and books related to global warming.
 

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