Day 012 - 18 Jul 94 - Page 77


     
     1
              Spontaneously, quite, as I recall, spontaneously it was
     2        come upon that doing a joint, that having a joint
              relationship in this deal would be good for both of us;
     3        for the Attorney General they get the benefit of being
              part of associated with McDonald's who is the only quick
     4        service restaurant to have made this type of dispersal of
              information and, for McDonald's, we get the benefit of
     5        being associated in a good situation with the Attorney
              General which was to our benefit also.
     6
         Q.   But people might think that the only reason you provided
     7        these booklets was because you were under some kind of
              threat from the New York Attorney General?
     8        A.  You say that, but none of the press releases or
              information given out by the Attorney General support
     9        that.  It just was not the case, though, is what I am
              saying.
    10
         MR. MORRIS:  Just to go back to point one in this document on
    11        page 189:  You said that this decision to put the booklets
              in your restaurants was a culmination of a process going
    12        back years.  You do not remember the date of that actual
              decision to put nationwide booklets in the stores?
    13        A.  You know, I don't.  I looked at the letter now in -- I
              mean, I was involved in the preparation, or reviewed the
    14        letter before it was sent out and ensured that we had
              specific support for those statements, but I just do not
    15        recall the exact date.
 
    16   Q.   Who made the decision?  Which body in the corporation made
              that decision?
    17        A.  Sorry, which?
 
    18   Q.   The decision that was made to put national leaflets in the
              stores, who made that decision?
    19        A.  It was made by the senior management of the
              corporation and, I suspect, a number of the senior
    20        managers, the vice presidents and senior vice presidents
              of operations of the corporation were involved.  It
    21        probably went throughout the entire corporation before we
              did that.
    22
         Q.   Right.  It was not just one or two people who took the
    23        decision on their own?
              A.  That is correct because putting 100 brochures which
    24        were first class brochures in 10,000 restaurants was a
              significant expense.
    25
         Q.   So the decision was probably made at the highest level 
    26        then? 
              A.  Probably. 
    27
         Q.   So that the corporate minutes with the details of that
    28        decision available?
              A.  I would not -- when you say "at the highest level",
    29        not at that level.  I cannot imagine it would have been
              done at that level.  I was referring to vice president,
    30        senior vice president, perhaps the president of McDonald's
              USA.

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