Day 043 - 01 Nov 94 - Page 69


     
     1        Nutrition.  Before you look at it, can I ask you, do you
     2        recall how, in fact -- you told it was not terminated
     3        because of anything to do with the Attorneys General except
     4        that one of them may have been changed in one respect -- it
     5        did come to an end, the advertising campaign in the
     6        magazines in 1987?
     7        A.  I think it ran its course.  I mean, these kinds of
     8        campaigns, especially on a specific issue, usually run on a
     9        relatively shorter period of time than a long-term campaign
    10        which would run over, you know, five or six years.
    11
    12   Q.   You remember in that coloured version you have there it did
    13        say at the beginning, I think, that it was intended to run
    14        for the year?
    15        A.  Yes.  Not only do I remember it ran for the year and it
    16        also ran the year afterwards, and we have done this kind of
    17        advertising on and off through 1991/1992.
    18
    19   Q.   That said, can you turn to the second tab of this yellow
    20        bundle?
    21
    22   MR. JUSTICE BELL:  I think I would like to ask a question about
    23        that.  Have you known for some time that there has been an
    24        issue in this case -- it is one of very many issues - as to
    25        whether The Time campaign was cut short because of pressure
    26        from Attorneys General?
    27        A.  Yes.  Yes, I have had discussion about it.
    28
    29   Q.   Has a search been made for any documentation, particularly
    30        contemporary documentation, which might throw light one way
    31        or the other on that?
    32        A.  Yes, all the materials that I would have, and all the
    33        materials that I believe that were in the department or
    34        outside of the department, we tried to produce so that you
    35        would have as much materials as you possibly could.
    36
    37   MR. RAMPTON:  Do you happen to know where those Leo Burnett
    38        memos that we have came from, that we just looked at?
    39        A.  No.  I would imagine they were either in our files or
    40        in the Leo Burnett files.
    41
    42   Q.   I will ask you, if I may, a more general question about
    43        McDonald's policy and the policy of your department, in
    44        particular, in relation to documentation:  How much
    45        documentation is generated by your department in the course
    46        of a year?
    47        A.  I am not sure what you mean by "documentation".  There
    48        are memos that are everywhere, yes.
    49
    50   Q.   You receive a lot and you send a lot? 
    51        A.  Yes, I receive a lot of memos.  In fact, most of the 
    52        memos that I receive, unfortunately, unless they are 
    53        something very specific that I should know about, are filed
    54        away or not read.
    55
    56   Q.   I was going to say when you say "filed away", what do you
    57        mean by that?
    58        A.  They are sort of put in what we would call the
    59        "circular file".  They are thrown away.
    60

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