Day 013 - 19 Jul 94 - Page 18


     
     1
         Q.   But you did send, did you not, a letter on July 3rd, which
     2        Helen read out, to all owner operators etc. etc., i.e. to
              every store enclosing the brochure.  It says:  "By way of
     3        background, ... as you know, the enclosed brochure
              ('McDonald's Food - The Facts'") etc. etc..  So, in fact,
     4        if it had been genuinely available there was nothing to
              stop you enclosing a hundred copies or a thousand copies
     5        with each one of those letters on July 3rd, which we claim
              you rushed out to pretend to be ahead of the Attorneys
     6        General.  I am trying to put my case because you asked me
              to put my case.
     7
         MR. JUSTICE BELL:  Yes, I know.  Let us take it step by step.
     8        It is suggested that you rushed out the booklet to beat
              the Attorneys General to the draw really.  What do you say
     9        about that, first of all?
              A.  I would ask for just a little bit more clarification
    10        on the question; "to beat them to the draw" in connection
              with ----
    11
         MR. MORRIS:  That has already been gone over by Helen last
    12        time, but the point I am making is on July 3rd 1986 when
              you wrote to what you call the McDonald's family?
    13        A.  Yes.
 
    14   Q.   Then why were not the brochures distributed at that time
              in large numbers seeing, as you say, you were planning to
    15        do it months and months before anyone ever mentioned it?
              A.  I do not recall.
    16
         Q.   Let us just move on.  One question on a general subject:
    17        Do you know when supermarket labelling of ingredients
              became compulsory in America on all products?
    18
         MR. JUSTICE BELL:  Just before we leave that, what you are
    19        really saying, is it, that the plan was not to get it out
              nationwide before October, but they had brought it forward
    20        very quickly at or about the end of June or beginning of
              July to beat the Attorneys General to the draw.  Is that
    21        what you are saying?
 
    22   MR. MORRIS:  Basically, yes.
 
    23   MR. JUSTICE BELL:  What do you say about that?
              A.  My recollection is that when we had the production
    24        completed, we rushed to put it in.  It is not a situation
              where you can say:  Print a million of these up very
    25        quickly so we can have them next week.  This is something
              I run across all the time in connection with our 
    26        advertising.  These things take a great deal of advance 
              notice -- just like placing magazine ads -- have to be 
    27        done three months in advance.  Once they are done they are
              done.  It is not my recollection that we ran from October
    28        until early August in order to beat out the Attorneys
              General.
    29
         MR. MORRIS:  Could you just tell me, do you know when
    30        supermarket labelling became compulsory in America for all
              ingredients?

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