Day 164 - 26 Sep 95 - Page 36
1 how serious and effectively they take those complaints. It
2 has become the subject of dispute in the case. Mr. Logan
3 has raised all kinds of questions about this in his
4 statement under health and safety about the causes of such
5 complaints being the over-crowding on the grills. That is
6 on pages 6 and 7 of his statement.
7
8 MR. JUSTICE BELL: Yes.
9
10 MR. MORRIS: Also the chicken vats, chicken McNuggets vats being
11 unreliable.
12
13 MR. JUSTICE BELL: Yes, I have read all that.
14
15 MR. MORRIS: I think that Mr. Logan is going to come and give
16 that evidence in court, to see the exact nature of the
17 complaints and the regularity, and that we should be able
18 to question both Mr. Richards and Mr. Logan about how the
19 complaints were investigated, if indeed they were
20 investigated. I think we have had a case in the past that
21 McDonald's investigations depend on quite strict criteria
22 before they even investigate.
23
24 MR. JUSTICE BELL: Yes.
25
26 MR. MORRIS: Also it might be worth noting that I think it was
27 Mr. Atherton or Mr. Kenny said they have something like
28 2,500 complaints a year, food poisoning complaints,
29 something like that, and if once a week is a more realistic
30 average for a store, that would be 25,000 complaints a year
31 or more.
32
33 I think that completes that.
34
35 MR. JUSTICE BELL: Are you moving on to another topic of
36 discovery?
37
38 MR. MORRIS: Yes.
39
40 MR. JUSTICE BELL: Because I think it would help me and might
41 help you if I asked Mr. Rampton if he wanted to reply.
42 Mr. Rampton, you last replied in respect of the Towers and
43 Perrin report.
44
45 MR. RAMPTON: Yes.
46
47 MR. JUSTICE BELL: I did not ask you what you wanted to say
48 about any witness statements in Lyons.
49
50 MR. RAMPTON: Would your Lordship like me to say something about
51 that?
52
53 MR. JUSTICE BELL: Whatever you wish.
54
55 MR. RAMPTON: It would not be very much. First of all, one has
56 to remember what the corporate or business structure is in
57 this particular case. The case concerned a wholly owned
58 franchise. By saying "wholly owned franchise", I mean a
59 franchise in which neither the Plaintiffs in this case had
60 any interest, so far as I know nor did the French
