Day 008 - 07 Jul 94 - Page 60


     
     1        A.  Yes, you could.
 
     2   Q.   In America?
              A.  Yes, we could say it is the largest.
     3
         Q.   You would have said it was the largest?
     4        A.  In our industry.
 
     5   Q.   "With our all cartons being manufactured from 100 per cent
              recycled paper, wherever the required application ..." If
     6        that statement had been made in America, in September
              1989, how would it have been expressed?
     7        A.  It would have been expressed differently.
 
     8   Q.   How would you have put it?
              A.  I do not have the facts, but I know that you are
     9        referring to cartons made from 100 per cent recycled
              paper?
    10
         Q.   Yes.
    11        A.  We would not make that claim.
 
    12   MR. JUSTICE BELL:  What is the claim -- maybe you cannot say?
              A.  Not fully, not a 100 per cent.
    13
         Q.   But what would "all our cartons" mean, because in the next
    14        paragraph it says:  "No recycle board is approved for use
              in direct food contact applications"?
    15        A.  Correct.  It could mean two things:  I think it means
              -- because people call corrugated containers different
    16        things in different countries -- they could be referring
              to "cartons" as a shipping container, that could be, or
    17        they might be referring to the non-direct food packaging
              "cartons".
    18
         MR. RAMPTON:  I think that is probably right.  You read the
    19        next paragraph:  "However, to date, for example, no
              recycling board is approved for use in direct food contact
    20        applications. They are currently working with our
              suppliers to provide a food grade recycle board to replace
    21        those items currently served in the cardboard"?
              A.  Yes.
    22
         Q.   That is in Australia.
    23        A.  Right. Most paper board I can think of is used, at
              least in our consumer package, for direct food packaging.
    24        I am trying to think of things that would not be direct
              food packaging.  I cannot think of an example.
    25
         Q.   Then I am unable, for reasons beyond my control, to show 
    26        you any US document for 1989.  I can show you a couple 
              from 1990 which are in the same file, first of all, 
    27        section 31.
 
    28   MR. JUSTICE BELL:  We will hear more about that.  I must say,
              I find that answer rather confusing.  If I read only the
    29        first paragraph, I would have thought it referred to all
              cartons, whether cartons which might contain food handed
    30        out to a customer, or a carton which brought produce into
              the restaurant or material into the restaurant.

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