Day 255 - 23 May 96 - Page 31
1 and saying that they are keen to avoid any unnecessary
2 legal costs because they have very limited resources and
3 saying that they have no desire to publish criticisms of
4 the company?
5 A. Yes.
6
7 Q. If they are not true. On the second page of the letter at
8 number 6 they ask the question: "With reference to the
9 fourth sentence of the statement" and that is the policy
10 statement?
11 A. Yes.
12
13 Q. "Does McDonald's use cleared rainforest for beef production
14 when the land has been deforested for the purposes other
15 than beef production within the last 50 years".
16
17 Then they go on in the next page in number 7 to say:
18
19 "With reference to the fifth sentence of the statement,
20 how does McDonald's define 'recent'? For example, one
21 week, month, year or longer?"
22
23 There is a response to this letter, following on from that,
24 dated 28th February 1990?
25 A. Yes.
26
27 Q. And at the bottom of that first page, the solicitors say
28 that they are prepared to answer the questions relating to
29 rainforest destruction?
30 A. Yes.
31
32 Q. Would they have come through you to get this information?
33 Presumably they would have if you were the person dealing
34 with it?
35 A. I cannot remember. I cannot remember this
36 correspondence at all.
37
38 Q. Right, but under your general instructions anyway. Do you
39 see the answer to number 7 is a significant number of
40 years?
41 A. Yes. I do not know who would have supplied them with
42 that.
43
44 Q. You cannot offer any explanation as to why, if the Company
45 knew what its definition of "recent" was, that did not get
46 conveyed to the Company solicitors?
47 A. No. As I say, I cannot remember this correspondence,
48 so I do not know where the information came from on which
49 Barlows framed their response.
50
51 Q. OK. If we go back to the "words complained of" bundle?
52 A. Yes?
53
54 Q. Tab 39, Hatfield Poly, which is undated, but action was
55 taken in February 1990. Do you remember that one?
56 A. No. What date, sorry?
57
58 Q. It says action was taken in February 1990.
59 A. Yes. This was a period, I think I have said before,
60 when I was in and out of work suffering from an illness.
