Day 067 - 15 Dec 94 - Page 28


     
     1        single form, that has been produced in the last 40 years.
     2
     3   Q.   Who was your predecessor?
     4        A.  Predecessor in what sense?  Let me see if I understand
     5        your question, who work on this area before me?
     6
     7   Q.   Yes.
     8        A.  There has been a number of people who had worked before
     9        me.  There are people that are current that was added to
    10        the staff, and there is another person, Paul Simmonds, who
    11        you have heard from him yesterday, who has been with the
    12        company for roughly 10 years.  There are some people who
    13        have been with the company, have left the company.  There
    14        are people who have been prior to me who have retired.
    15
    16   Q.   So when you took on your job, was that a new position that
    17        was created or were you taking over somebody else's, like
    18        somebody was leaving?
    19        A.  No.  When I was hired there was a need to add some
    20        people resources in the corporate offices.  I would say
    21        that I was to work primarily in the beef and chicken area.
    22        We just needed more people.  The people that had that
    23        responsibility before me are still there, that is Paul
    24        Simmonds.
    25
    26   Q.   So did he mention to you any similar surveys such as this,
    27        the one we looked at yesterday?
    28        A.  I had some conversation with him when we developed the
    29        format.  I developed that format following the guidelines
    30        of the Humane Slaughter Act, and I wanted to answer
    31        directly the allegations that were made by you, so
    32        I developed that form of thinking in those terms.  I do not
    33        recall -----
    34
    35   Q.   It was done specifically for this court case?
    36        A.  Yes.  I do not recall having a conversation with
    37        Mr. Simmonds about any previous forms.
    38
    39   Q.   So you did not already have the information on record to be
    40        able to answer the questions that are found in those forms?
    41        A.  Personally?
    42
    43   Q.   As a company?
    44        A.  As a company, I hope you would understand that a
    45        company of our size generates a lot of paper work, a lot of
    46        reports.  We have a guideline that we basically dispose of
    47        our documents every three years simply because we do not
    48        have room for them.  It would be an unfair statement to say
    49        that I did not have access to the previous documents that
    50        could have been generated previous to myself joining 
    51        McDonald's. 
    52 
    53   Q.   There was nothing you could find that had been done in the
    54        three years before you did this survey?
    55        A.  I looked at many things when I developed that form.
    56        I looked at -- concentrated in the Humane Slaughter Act;
    57        I concentrated on the allegations that were made;
    58        I consulted with the trade associations; I have consulted
    59        with Texas A & M; I have consulted with consultants, with
    60        many people, so I could better understand the implications

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