Day 067 - 15 Dec 94 - Page 51


     
     1   MR. MORRIS:  Yes.  Do you know what has happened with the
     2        European forms?
     3        A.  What happened in terms of how they progressed?
     4
     5   Q.   Did they not fill them in or did they fill them in but they
     6        were not used?
     7        A.  I do not know to be honest.  There were probably some
     8        people who did not answer.  There could be some that sent
     9        it to a different fax.  I do not know.
    10
    11   Q.   You sent these forms to every country, yes?
    12        A.  Yes, I did.
    13
    14   Q.   Did you explain to them that it was important to fill in,
    15        that it is for a court case?
    16        A.  When I sent, if I remember correctly, the cover letter
    17        that went with this I explained that the intent was to get
    18        an estimation of some of the practices around the world.
    19        That is what I said.  One of the concerns that I have when
    20        I send written material, once you put it in writing, once
    21        you circulate it, you lose control of it.  There is
    22        significant confidential information that can be mishandled
    23        that I am in possession, that I circulate, that can be
    24        misunderstood.  It is for that reason that I do not go into
    25        detail as to what is everything or the importance or
    26        everything that will cover that letter.  I would prefer to
    27        have a private conversation or a telephone conversation.
    28        We have a voice mail system where we communicate with our
    29        peers around the world.
    30
    31   Q.   Yes, but in terms of this form which you sent out to every
    32        country, did you tell them it was for a court case?
    33
    34   MR. JUSTICE BELL:  Well, you did because if you look at O it
    35        says so.
    36        A.  What I remember in the cover letter that it was part of
    37        a litigation.
    38
    39   MR. MORRIS:  Anyway, we are on Malaysia.  If we look at the
    40        second page of Malaysia which is beef, the imports from
    41        Australia, processed in Malaysia and then used in Hong Kong
    42        and Malaysia, yes, is that correct?
    43        A.  I do not know about this particular time it was used in
    44        Hong Kong.  I do know that they do buy raw materials from
    45        Australia.  I do know they are processed in Mac Foods.
    46        Sometimes we have sent product from there to Singapore in
    47        Hong Kong.
    48
    49   Q.   So this third blob which says "Products exported to
    50        country", that means the country that they were at that 
    51        time exporting to for McDonald's use? 
    52        A.  That is correct. 
    53
    54   Q.   Over the page we then have Singapore, as you said, and that
    55        is with raw material from China.  There are a lot of yes's
    56        throughout these documents.  Would it be fair to say that
    57        the people filling this in are the people from McDonald's,
    58        are they not?
    59        A.  That is correct.
    60

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