Day 246 - 09 May 96 - Page 25


     
     1        is won?"
     2
     3        At that time, you were expecting to get damages if you won
     4        the case?
     5        A.  We talked through this discharge issue quite
     6        extensively yesterday.  The entitlement to damages is
     7        certainly there if we win.  What they might be or whether
     8        we choose to ----
     9
    10   MR. JUSTICE BELL:  I do not want you to repeat what you said
    11        yesterday, Mr. Preston, unless it is vital to your answer.
    12
    13        All you are being asked, having read the paragraph 1.1, is
    14         ----
    15
    16   MS. STEEL:  Basically you were still seeking damages at that
    17        time?
    18
    19   MR. JUSTICE BELL: -- you were expecting to get your damages if
    20        you won the case and were awarded damages?
    21        A.  Yes.
    22
    23   MS. STEEL:   In No. 2 it talks about:
    24
    25        "Should be produced a briefing paper for the media that
    26        could be faxed in response to inquiries or offered
    27        pro-actively to a selected number of target journalists."
    28
    29        At that time who were -- I do not know mean who
    30        individually -- were the would-be the targeted
    31        journalists?  Were they ones that had been sympathetic to
    32        McDonald's previously?
    33        A.  I do not know who they would be talking about.  "In
    34        response to inquiries" could come from anybody.
    35        "Pro-actively offered to selective", I do not know.  They
    36        may have been talking about the national media.  They may
    37        have been talking about local, I do not know.
    38
    39   Q.   Then on page 10, which is the second page of this
    40        particular document, under "Local Media Coverage":
    41
    42        "What impact will local coverage have on restaurants and
    43        how will staff deal with customers questions?  Should we
    44        have a leaflet prepared for handing out in response to
    45        questions, or even included in the leaflet dispensers?"
    46
    47        You are aware at that time that the Company was considering
    48        putting them, or intending or thinking about putting them
    49        out in the leaflet dispensers rather than just having them
    50        behind the counter? 
    51        A.  Yes. 
    52 
    53   Q.   Why was it that Company decided, as you claim, not to have
    54        them put in the leaflet dispensers?
    55        A.  They were prepared.  They were to be used for response
    56        to questions by customers.  We feed something like a
    57        million and a half people a day and if we gave them out to
    58        every customer It would not last but a few hours in the
    59        first day; 300,000 leaflets was intended to deal with
    60        specific questions.  It is a matter of logistics.

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