Day 255 - 23 May 96 - Page 31


     
     1        and saying that they are keen to avoid any unnecessary
     2        legal costs because they have very limited resources and
     3        saying that they have no desire to publish criticisms of
     4        the company?
     5        A.  Yes.
     6
     7   Q.   If they are not true.  On the second page of the letter at
     8        number 6 they ask the question: "With reference to the
     9        fourth sentence of the statement" and that is the policy
    10        statement?
    11        A.  Yes.
    12
    13   Q.   "Does McDonald's use cleared rainforest for beef production
    14        when the land has been deforested for the purposes other
    15        than beef production within the last 50 years".
    16
    17        Then they go on in the next page in number 7 to say:
    18
    19        "With reference to the fifth sentence of the statement,
    20        how does McDonald's define 'recent'?  For example, one
    21        week, month, year or longer?"
    22
    23        There is a response to this letter, following on from that,
    24        dated 28th February 1990?
    25        A.  Yes.
    26
    27   Q.   And at the bottom of that first page, the solicitors say
    28        that they are prepared to answer the questions relating to
    29        rainforest destruction?
    30        A.  Yes.
    31
    32   Q.   Would they have come through you to get this information?
    33        Presumably they would have if you were the person dealing
    34        with it?
    35        A.  I cannot remember.  I cannot remember this
    36        correspondence at all.
    37
    38   Q.   Right, but under your general instructions anyway.  Do you
    39        see the answer to number 7 is a significant number of
    40        years?
    41        A.  Yes.  I do not know who would have supplied them with
    42        that.
    43
    44   Q.   You cannot offer any explanation as to why, if the Company
    45        knew what its definition of "recent" was, that did not get
    46        conveyed to the Company solicitors?
    47        A.  No.  As I say, I cannot remember this correspondence,
    48        so I do not know where the information came from on which
    49        Barlows framed their response.
    50 
    51   Q.   OK.  If we go back to the "words complained of" bundle? 
    52        A.  Yes? 
    53
    54   Q.   Tab 39, Hatfield Poly, which is undated, but action was
    55        taken in February 1990.  Do you remember that one?
    56        A.  No.  What date, sorry?
    57
    58   Q.   It says action was taken in February 1990.
    59        A.  Yes.  This was a period, I think I have said before,
    60        when I was in and out of work suffering from an illness.

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