Day 139 - 21 Jun 95 - Page 57


     
     1        A.  OK.
     2
     3   Q.   At the top of the paragraph, page 11.  The reality is you
     4        wanted to get rid of the union?
     5        A.  No.
     6
     7   Q.   That is why you went there, did you not?
     8        A.  No, I did not, not at all.  I wanted to solve a problem
     9        that existed before I got there.
    10
    11   Q.   The problem was the operational standards were very poor?
    12        A.  No.  There was a labour problem that existed and I was
    13        being asked by Mr. Miller to please come and help him sort
    14        the thing out.
    15
    16   Q.   So the union was the problem?
    17        A.  What problem?  You know ----
    18
    19   Q.   You have said there was a problem.  You went there to solve
    20        a problem, you have said yourself, in your statement?
    21        A.  You know, would you please start asking questions that
    22        make sense, that have some order to them, have some meaning
    23        to them?
    24
    25   Q.   You have said ----
    26        A.  It is getting late in the day and, frankly, I am
    27        getting tired of this nonsense.
    28
    29   MR. JUSTICE BELL:  Just calm down, Mr. Stein.  Collect
    30        yourself.  You must have had far tenser days in court as an
    31        attorney.
    32        A.  But more meaningful days, my Lord.
    33
    34   Q.   No, do not start saying things like that.  What is being
    35        put to you is that you went out there because there was a
    36        labour problem?
    37        A.  That is correct.
    38
    39   Q.   As McDonald's saw it, being that ----
    40        A.  As Mr. Miller saw.
    41
    42   Q.   -- the union agreement was drawing to its conclusion and
    43        you did not want a new one.  That is what you are putting,
    44        is it not, Mr. Morris?
    45        A.  In answer to that question ----
    46
    47   MR. JUSTICE BELL:  Just pause a moment.
    48
    49   MR. MORRIS:  I am sorry -- yes, that is exactly what I am
    50        saying. 
    51 
    52   MR. JUSTICE BELL:  Let me put it to you again.  What is 
    53        suggested is that you knew that the Gibson union agreement
    54        was coming to an end and you, the embodiment of McDonald's,
    55        did not want it renewed and that is why you went to Puerto
    56        Rico?
    57        A.  The answer is:  No, that is not why I went to Puerto
    58        Rico.
    59
    60   MR. MORRIS:  You went to Puerto Rico to discuss the problem with

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