Day 012 - 18 Jul 94 - Page 11


     
     1        document headed: "Nutritional Analysis of Foods Served at
              McDonald's Restaurants, Hazelton laboratories American,
     2        Inc." Do you see that?
              A.    Yes.
     3
         Q.   I am not going to attempt to disentangle what is inside
     4        it. Was that the document referred to on page 95?
              A.    Yes, I believe so.
     5
         Q.   Can we go back, please, then to tab B?
     6
              A.    Right.
     7
 
     8   Q.   You should be at 186D.  Can you turn to 186D?
              A.    Yes, I am there.
     9
         Q.   Can you go to 186F which is the last page of the letter?
    10        A.    OK, item 186F.
 
    11   Q.   Yes.  "Each brochure should contain a telephone number
              which customers can call for further ingredients or
    12        nutrition information, preferably with an 800 number".  I
              cannot remember whether it was 800 number?
    13        A.    No, it was not.
 
    14   Q.   That is what we saw earlier.  Going on:  "We sincerely
              hope that you agree that the program we have outlined
    15        above is workable in your chain on a systemised basis.  If
              you are agreeable to resolving this matter in the manner
    16        outlined, please contact us in writing within two weeks,
              indicating your agreement and  detailing those steps you
    17        will implement.  If we do not hear from you within that
              time, we will assume your firm is not interested in
    18        reaching an informal conclusion to our discussions.  We
              will continue to weigh the other options open to our
    19        office".  What did you understand by that last sentence-
               "the other options open to their offices"?
    20        A.    Yes, if we do not hear from you ---- The other
              options are to sue us.
    21
         Q.   Did they ever indicate in the meeting with you that they
    22        might sue you if you did not do what you were told?
              A.    Well, that threat was always present.
    23
         Q.   What I want to ask you is this:  How far was this
    24        distribution, eventually nationwide of these booklets,
              prompted by a fear of prosecution or suit from the
    25        Attorneys General?
              A.    It was not prompted at at all by the Attorneys 
    26        General. As a matter of fact, at this time in connection 
              with this letter, this was more a general letter.  My 
    27        understanding is they sent out to all of the quick service
              restaurants they had spoken to.  In fact, almost without
    28        exception everything that was required and requested by
              this letter had already been incorporated in the material
    29        we were already distributing.  We always guessed they were
              using us as the standard for writing this letter.
    30
         Q.   One final thing, if we turn to the next document, you

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