Day 095 - 02 Mar 95 - Page 62


     
     1   Q.   It went on for some considerable time and you said this:
     2        "We have in the US, for example, product specification
     3        that will override (whatever it was that was being
     4        suggested) that will, say our suppliers, who will use, must
     5        use 100 per cent domestic beef.  It has been in our
     6        specification as far as I can remember since 1955 or 56.
     7        It is for that reason we say as much as possible." I do not
     8        know what it is a reference to. Question: "While we are on
     9        that subject, have you seen a regulation specification
    10        dating back to 1954/56 only 100 per cent domestic beef in
    11        the USA." Your answer:"I am not sure.  Let me see if I can
    12        understand your question. You said regulation or
    13        specification.  You got me confused."  Mr. Morris then says
    14        that he means specification, and so it goes on.  What
    15        I wanted to do is to ask you to look at some documents, as
    16        I did not a moment ago, in pink IX first of all, please.
    17        Please turn to tab 2A first of all.
    18
    19   MR. JUSTICE BELL:  McDonald's Meat Specifications.
    20
    21   MR. RAMPTON:  It is McDonald's Meat Specifications.  Do you have
    22        that?
    23        A.  Yes, I do.
    24
    25   Q.   It should be a three-page document, is it?
    26        A.  Yes.
    27
    28   Q.   Does it have a rather bad drawing of a rather old fashioned
    29        looking McDonald's restaurant in the top left-hand corner?
    30        A.  That is correct.
    31
    32   MR. MORRIS:  I have not got a copy of this.
    33
    34   MR. RAMPTON:  I can tell you this, Dr. Gomez Gonzalez, well,
    35        perhaps I will not tell you this.  Just glance at the
    36        document, particularly perhaps the first page and the
    37        second page.  Do you think that you have seen anything like
    38        that before?
    39        A.  Yes, I have seen this document before.
    40
    41   Q.   You have?
    42        A.  Yes.
    43
    44   Q.   Right.  Then look over the page to page 2.  Do you see
    45        paragraph D at the top of the page: "Ingredients absolutely
    46        not to be used" right-hand column, No. 8 "imported beef"?
    47        A.  Yes, I do.
    48
    49   Q.   Then please turn to tab 2B in that same bundle.  It should
    50        be a very short two-page document, a sideways document, 
    51        McDonald's Fresh Regular Quarter Pounder, yes?  McDonald's 
    52        Fresh Regular Patty Quarter Pounder Patty Specifications, 
    53        do you have that?
    54        A.  Yes, I do.
    55
    56   MR. JUSTICE BELL:  I do not have that one.
    57
    58   MR. RAMPTON:  I will read it out first and then I will ask you
    59        whether you think you have seen it before.  Under "D" in
    60        the left-hand column it says: "Ingredients absolutely not

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