Day 127 - 23 May 95 - Page 21


     
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     2   MR. JUSTICE BELL:  Can you speak up load and clear?  It is no
     3        doubt my fault, but I do not find it easy to catch every
     4        word you say.  Direct your answers at Mr. Rampton because
     5        he is pretty central.  Keep your vice right up.
     6
     7   MR. RAMPTON:  If it is not too far out of character,
     8        Mrs. Barnes, can you imagine shouting at me because
     9        I also  ------
    10
    11   MR. JUSTICE BELL:  She can probably imagine that only too
    12        easily, Mr. Rampton.  Just keep your voice up.
    13
    14   MR. RAMPTON:  Can we just have a look at some early documents in
    15        this file, please, Mrs. Barnes?  The first one is the first
    16        page 716 at the bottom.  It may be easier for you if you
    17        put that file on the stand in front of you.  Is that a
    18        memorandum from Keith Smith to all Store Managers dated
    19        15th November 1990?
    20        A.  It is.
    21
    22   Q.   This mentions the new regulations, does it not?
    23        A.  It does.
    24
    25   Q.   Please turn over the page.  We have jumped a few months and
    26        we are in March 1991.  Again, this comes from Frank Frost.
    27        Tell us who Frank Frost is.
    28        A.  Frank Frost is the Facilities Engineer in the Northern
    29        region.  He runs the Equipment Department in that region.
    30
    31   Q.   Do you know whether similar memos will have gone out in
    32        other regions?
    33        A.  Yes, they will.  The way that it works is that Frank
    34        and the other two Facilities Engineers report into the
    35        Company Equipment Manager, but they all send out their
    36        information regionally unless very occasionally Richard
    37        Rowley, who is the Equipment Manager, will send out a
    38        corporate memo, but usually they all duplicate them
    39        regionally.
    40
    41   Q.   There is one on the previous page, 716, looks -- who is
    42        Keith Smith?
    43        A.  Keith Smith is the Company Services Engineer.
    44
    45   Q.   So is this a corporate memo?
    46        A.  That is a corporate memo from him and he is a qualified
    47        electrical engineer.
    48
    49   Q.   We can see that mode of dissemination at the bottom of the
    50        page; Regional Manager, Market Managers, Operations 
    51        Managers, Senior Supervisors and licensees for information? 
    52        A.  Yes. 
    53
    54   Q.   Pausing there, a slight digression:  What is the
    55        relationship between McDonald's, the Company, and the
    56        licensees in relation to health and safety?
    57        A.  With health and safety, my Department, for example,
    58        would be here to advise them, and what we would always
    59        advise them is that they follow the Company line.  They
    60        generally do that.  Often, we have to put a very reasoned

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