Day 067 - 15 Dec 94 - Page 28
1 single form, that has been produced in the last 40 years.
2
3 Q. Who was your predecessor?
4 A. Predecessor in what sense? Let me see if I understand
5 your question, who work on this area before me?
6
7 Q. Yes.
8 A. There has been a number of people who had worked before
9 me. There are people that are current that was added to
10 the staff, and there is another person, Paul Simmonds, who
11 you have heard from him yesterday, who has been with the
12 company for roughly 10 years. There are some people who
13 have been with the company, have left the company. There
14 are people who have been prior to me who have retired.
15
16 Q. So when you took on your job, was that a new position that
17 was created or were you taking over somebody else's, like
18 somebody was leaving?
19 A. No. When I was hired there was a need to add some
20 people resources in the corporate offices. I would say
21 that I was to work primarily in the beef and chicken area.
22 We just needed more people. The people that had that
23 responsibility before me are still there, that is Paul
24 Simmonds.
25
26 Q. So did he mention to you any similar surveys such as this,
27 the one we looked at yesterday?
28 A. I had some conversation with him when we developed the
29 format. I developed that format following the guidelines
30 of the Humane Slaughter Act, and I wanted to answer
31 directly the allegations that were made by you, so
32 I developed that form of thinking in those terms. I do not
33 recall -----
34
35 Q. It was done specifically for this court case?
36 A. Yes. I do not recall having a conversation with
37 Mr. Simmonds about any previous forms.
38
39 Q. So you did not already have the information on record to be
40 able to answer the questions that are found in those forms?
41 A. Personally?
42
43 Q. As a company?
44 A. As a company, I hope you would understand that a
45 company of our size generates a lot of paper work, a lot of
46 reports. We have a guideline that we basically dispose of
47 our documents every three years simply because we do not
48 have room for them. It would be an unfair statement to say
49 that I did not have access to the previous documents that
50 could have been generated previous to myself joining
51 McDonald's.
52
53 Q. There was nothing you could find that had been done in the
54 three years before you did this survey?
55 A. I looked at many things when I developed that form.
56 I looked at -- concentrated in the Humane Slaughter Act;
57 I concentrated on the allegations that were made;
58 I consulted with the trade associations; I have consulted
59 with Texas A & M; I have consulted with consultants, with
60 many people, so I could better understand the implications
