Day 059 - 01 Dec 94 - Page 36


     
     1        first replaced Isopentane?
     2        A.  In 1986.
     3
     4   Q.   You may already have said that.
     5        A.  I did.
     6
     7   Q.   It is my fault for not listening because I do not look at
     8        the screen all the time.  Can you then open this file which
     9        I think is No. 5 at tab 28B?  Do you have a letter dated
    10        29th June 1987 from Lin Pac Plastics to Mr. Wootton?
    11        A.  Yes, I do.
    12
    13   Q.   The letter is signed by Mr. B.C. Marshall or it might be
    14        Mrs. Marshall, for all I know, the General Sales Manager;
    15        is that right?
    16        A.  Yes, it is David Marshall.
    17
    18   Q.   David Marshall.  This is, apparently, Mr. Ted Wootton who
    19        is the addressee.  Who is or was Mr. Wootton?
    20        A.  Mr. Ted Wootton was at that time a Senior Buyer within
    21        the UK Purchasing Department and today is, in fact,
    22        Department Head and Purchasing Manager of that department.
    23
    24   Q.   Was he, as it were, working with you at this time in 1987?
    25        A.  Yes, he was.  I was Department Head at that time, so he
    26        reported directly to me.
    27
    28   Q.   This is dated 29th June 1987.  It reads -- I am not going
    29        to read the whole of it:  "Dear Ted, further to our recent
    30        meeting, I would like to confirm the points we discussed.
    31        Should the decision be made to change back to Pentane, the
    32        approximate cost £88,000 for one line, broken down as
    33        follows", then he breaks it down and gives the total at the
    34        bottom.  I do not know if I read the heading, "Freon to
    35        Pentane", but anyway I repeat it if I did.  What is or was
    36        "Freon"?
    37        A.  They are referring to the blowing agent.
    38
    39   Q.   What kind of a chemical substance is "Freon"?
    40        A.  That would contain CFCs.
    41
    42   Q.   And Pentane is a hydrocarbon?
    43        A.  Is a hydrocarbon, yes.
    44
    45   Q.   He writes:  "Should the decision be made to change back to
    46        Pentane", were you involved in any kind of decision-making
    47        process -- you yourself -- at that time about a change from
    48        Freon to Pentane?
    49        A.  Prior to that time, yes.  That is when I instructed Lin
    50        Pac to make the change. 
    51 
    52   Q.   This is in some time then before 29th June 1987? 
    53        A.  That is right.  It was more or less in the summer of
    54        1987 I met with Lin Pac.
    55
    56   Q.   The Montreal Protocol -- this is undisputed and, in fact,
    57        indisputable -- was, in fact, signed on 16th September of
    58        that year, 1987.  What was it, Mr. Oakley, that prompted
    59        you and your company, McDonald's, to consider making a
    60        change away from CFCs to hydrocarbons before ever the

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