Day 008 - 07 Jul 94 - Page 49


     
     1   MR. RAMPTON:  Yes?
              A.  Of volume III.
     2
         Q.   The one we were looking at a moment ago?
     3        A.  You see that same 10,163 number used as the amount of
              recycled material used in 1988 for paper packaging.
     4
         Q.   So what Mr. Kouchoukos has done is to take the pulp trays
     5        which you tells are 100 per cent?
              A.  He took the only item we were 100 per cent into
     6        recycle content.
 
     7   Q.   If you want to know the total of recycle content for a
              particular year, yes?
     8        A.  Yes.
 
     9   Q.   Then you have to include those items which are only
              partially made of recycled material?
    10        A.  Either that or in some instances we might have
              materials that are one supplier makes recycled paper, the
    11        remaining suppliers do not.  We have a combination of
              efforts.
    12
         Q.   As you have both documents out, can you offer an
    13        explanation why for the year 1988 Mr. Kouchoukos gives a
              figure, a total figure, of tonnes for that year of
    14        147,173?  Do you see that?
              A.  Yes.
    15
         Q.   Whereas, in the other document which is produced at the
    16        time (or seems to have been) the total is much greater,
              162,877?
    17        A.  I cannot give an immediate answer to that; I do not
              know.
    18
         Q.   We may have to get in touch with Mr. Kouchoukos and ask
    19        him.  I have not got the calculator with me, but is 10,163
              roughly 7 per cent of 147,173?
    20        A.  That is what it looks like to me.
 
    21   Q.   I would like you to look at another document, bearing in
              mind the figure of 162,877, yes?
    22        A.  OK, sorry.
 
    23   Q.   Another document in bundle V, 55 -- I do not why you have
              a law book there ---
    24        A.  I was told to mark it, so.
 
    25   Q.   -- and turn to page 614?
              A.  Which volume is this? 
    26 
         Q.   Large Roman V of the pink volume.  Turn to page 614 in 
    27        section 31.
 
    28   MR. MORRIS:  Are we closing the other ones?
 
    29   MR. JUSTICE BELL:  No, keep them all open.  I know it is
              cumbersome but you will get completely lost.
    30
         MR. MORRIS:  Which one are we on now?

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