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.
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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 ------
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11 MR. JUSTICE BELL: She can probably imagine that only too
12 easily, Mr. Rampton. Just keep your voice up.
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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.
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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.
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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
