Day 013 - 19 Jul 94 - Page 24


     
     1        A.  Yes, that is my recollection.
 
     2   Q.   So it was quite prophetic.
 
     3   MS. STEEL:   What you just said, this was just the thoughts of
              Mr. Smedley.  Can you just read the first line of this
     4        document?  "These are the key points that we discussed at
              our meeting on Monday".
     5        A.  Yes, I believe what I said ----
 
     6   Q.   It goes on to list them.  Then at No. 4 it says:  "We all
              seem to agree that, if possible, McDonald's should attempt
     7        to deflect the basic negative thrust of our critics".  It
              does appear from that that unless Mr. Smedley was falsely
     8        representing what was discussed at the meeting, this was
              not just his view; it was the view of -- it was the
     9        feeling of the meeting?
              A.  This is Mr. Smedley.  I believe what I said was this
    10        was Mr. Smedley's synopsis or summary of what took place
              at the meeting in his own particular style, some of which
    11        I do not agree with.
 
    12   Q.   You were not at the meeting, were you?
              A.  No, quite frankly, as I mentioned before, I said this
    13        was communication, an outside consultant talking to our
              communications division inside McDonald's.  As I look down
    14        the list of carbon, of CCs on page 186, the only people
              that I seem to recognise here are communications, public
    15        relations people.  That is what they were looking at.
 
    16   Q.   From McDonald's or from Golin Communications?
              A.  The first one, second one, third one, fourth one from
    17        McDonald's.  I think the fifth and sixth -- Mr. Keyser was
              from McDonald's; Persel(?) I believe was from McDonald's
    18        and the last three, I believe, from Mr. Golin on down were
              from the agency.
    19
         Q.   You were not at this meeting; so are not in a position to
    20        say this is an inaccurate record of that meeting?
              A.  I was not at the meeting.  I cannot say anything about
    21        what happened at the meeting.
 
    22   MR. MORRIS:  Just one more point on this memo before we move
              on:  Point D:  Do you agree with this?  "We should
    23        seriously consider the wisdom  ... (reading to the
              words) ... in tests".  What is your opinion about this
    24        paragraph?
 
    25   MR. JUSTICE BELL:  You started off with a question and before
              he had a chance to answer it you started another. 
    26 
         MR. MORRIS:  It is hard to ----- 
    27
         MR. JUSTICE BELL:  Let him answer the first one and see whether
    28        you need to ask another.
 
    29   MR. MORRIS:  Do you think at that time you should have
              seriously considered the wisdom of officially talking
    30        about salads and tests?
              A.  I do not know how to answer that question.  I do not

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