Day 293 - 04 Nov 96 - Page 17


     
     1        Multiplying that by 20,000 stores worldwide, what they have
     2        now, something less before, and multiplying it by 364 days
     3        of the year, it would be something like a thousand million
     4        pounds of waste a year, possibly double if it does not
     5        include take-out.  It may even be greater in terms of if
     6        there is other waste which is not considered.  So we are
     7        talking about substantial amounts of packaging waste.
     8
     9   MR. JUSTICE BELL:   In very broad figures, since there are
    10        roughly 1,000 pounds in half a tonne - it is a bit more -
    11        there are 2,240 pounds in a tonne, are there not?  It is
    12        112 pounds a hundredweight.  Twenty hundredweights in a
    13        tonne.
    14
    15   MR. MORRIS:   Something like half a million tonnes, sort of
    16        minimum, multiplied by whatever percentage of packaging
    17        waste may be left out of the calculation from each store.
    18
    19   MR. JUSTICE BELL:   Yes.
    20
    21   MR. MORRIS:   (Pause) Sorry, I am just collecting my thoughts
    22        here.  In paragraph 11....  Well, there was some confusion
    23        between Mr. Kouchoucos and Mr. Langert which I could not
    24        get to the bottom of, over what percentage of paper was
    25        recycled in 1989 which we had been originally informed,
    26        I think, was 7 percent.
    27
    28   MR. RAMPTON:   My Lord, can I intervene here, because it does
    29        make things a bit shorter.  In consequence of that
    30        confusion, and I agree there was a confusion between the
    31        two of them, we got, if your Lordship remembers, a
    32        Civil Evidence Act statement from Mr. Kouchoucos.  I think
    33        it is in file yellow 12.  The Defendants have agreed the
    34        figures which he attaches at appendix 5 to that statement.
    35
    36   MR. MORRIS:   We never agreed any figures.
    37
    38   MR. RAMPTON:   We wrote to the Defendants about it a long time
    39        ago.  Eventually Mr. Morris responded and that was one of
    40        the many documents that he agreed.
    41
    42   MR. MORRIS:   No, we said subject to any cross-examination or
    43        dispute during the course of the court case.  We were not
    44        accepting at face value any document which had been
    45        specifically questioned or challenged.
    46
    47   MR. JUSTICE BELL:   What do you say -----
    48
    49   MR. MORRIS:   So do not assume that any document is
    50        automatically ----- 
    51 
    52   MR. JUSTICE BELL:   What do you say the net result of it was, 
    53        anyway?
    54
    55   MR. MORRIS:   The result of it is that I think you should look
    56        very carefully at the situation, because we are quite
    57        prepared to accept that the maximum recycled content was
    58        what Mr. Kouchoucos was stating, 7 percent.
    59
    60   MR. JUSTICE BELL:  7 percent?

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