Day 059 - 01 Dec 94 - Page 37


     
     1        Montreal Protocol was signed?
     2        A.  As I explained earlier, I have read the Antarctic
     3        Expedition Reports and I felt it prudent to make the
     4        change.  I thought it was inevitable that something like
     5        the Montreal Protocol would occur, and I personally
     6        thought, this was not a company direction, I personally
     7        thought it was a prudent thing to do environmentally.
     8
     9   Q.   As you have told us, the company were persuaded by you in
    10        due course.  Did you have much of a struggle?
    11        A.  I struggled all round at that time with the company and
    12        with Lin Pac, because nobody really wanted to take this
    13        situation as seriously as I saw it.
    14
    15   Q.   If we turn over two pages to page 510 X -- this time it
    16        really is an X -- a letter from Lin Pac dated 26th November
    17        1987 again to Mr. Wootton at McDonald's in this country;
    18        I only really want to ask you about the first part of it:
    19         "Dear Ted, on behalf of Peter and myself, it was a
    20        pleasure to meet you at Featherstone" -- that is where the
    21        plant is, the Lin Pac plant, in Yorkshire?
    22        A.  That is correct.
    23
    24   Q.   -- "today, when we had the opportunity to discuss the
    25        points raised at the meeting Peter had with Ed and yourself
    26        on 11th November".  Do you know, Mr. Oakley, who are the
    27        "Peter" and the "Ed" referred to in that paragraph?
    28        A.  "Peter" is Peter O'Shea who was then Production
    29        Director and "Ed" is myself.
    30
    31   Q.   Then he writes:  "I would like to cover the progress and
    32        steps taken as per the agenda".  I will come back to those
    33        words in a minute. "1.  Freon to Pentane.  We will be doing
    34        trials and will submit samples end December/early January",
    35        1988 that is, "but will not be in a position to switch
    36        totally until April as we have to alter the reclaim system
    37        so that we get complete segregation on Freon and Pentane
    38        scrap".   I am not going to ask you about that; the
    39        Defendants can if they are interested.  But what I want to
    40        know is, what does he mean, do you know, by his reference
    41        to "the agenda"?
    42        A.  I am sorry, say that again?
    43
    44   Q.   Do you know what Mr. Marshall means when he says:  "I would
    45        like to cover the progress and steps taken as per the
    46        agenda".  Do you know what he means by "the agenda"?
    47        A.  Well, the agenda he had for the meeting, presumably.
    48
    49   Q.   I see.  Then over the page.
    50 
    51   MR. JUSTICE BELL:  It is not an agenda in the sense of a timed 
    52        plan --- 
    53        A.  No, it was meeting agenda.
    54
    55   Q.   -- these things to fall into place?
    56
    57   MR. RAMPTON:  Then if you turn over, please, to 510 AA which is
    58        four pages on; 3rd December 1987 from Lin Pac to
    59        Mr. Wootton again.  I should have asked you this before
    60        moving on to this next letter about Mr. O'Shea and

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