Day 062 - 06 Dec 94 - Page 56


     
     1        will have the cutlery in there, plastic cutlery. It is
     2        basically the same cutlery, just without the extra
     3        wrapping.
     4
     5   MR. MORRIS:  We are sort of working through all the documents
     6        here.
     7
     8   MR. JUSTICE BELL:  Choose which ones are going to progress your
     9        argument.  There is no need to test something for the sake
    10        of it.  Pick out what you think assists the case you want
    11        to put.
    12
    13   MR. MORRIS:  I am on page 7.13.  We have already identified
    14        that, apart from the transport packaging which has now been
    15        noted, there are fry bags and place mats, promotional
    16        items, toilet rolls, kitchen towels, a few bits and pieces
    17        from the States, Happy Meal boxes, happy hats, napkin wraps
    18        which are not included in the figures and office
    19        stationery.  You cannot calculate that total volume missed
    20        out?
    21        A.  Napkin wraps have been included.  The bits and pieces
    22        from the States have been included.
    23
    24   Q.   Because they have gone through the DCs?
    25        A.  Yes, because they have gone through Perseco.  They
    26        come, then the supplier in this case was Perseco US instead
    27        of -- and then it comes through us and goes through the DCs
    28        or the sales go through, but they have been included.  You
    29        are quite right if you say that things like kitchen
    30        towels ----
    31
    32   Q.   Toilet rolls?
    33        A.  --- toilet rolls, place mats, tray liners, have not
    34        gone through us.
    35
    36   Q.   You can see where we are moving.  We are trying to identify
    37        the total volume.  It is very difficult to do that just
    38        based upon Perseco's figures.
    39
    40   MR. JUSTICE BELL:  Can you help any more on quantifying the
    41        extra?  You said you have no idea when I asked you.
    42        A.  Sorry, I know that most of these extras do go through
    43        some of the suppliers that we deal with, so there is a way
    44        for me to find out several of those items.  But it would be
    45        a difficult one to find out for going back at all because
    46        we have not dealt with them, and it would have to be
    47        determined afterwards.  Kitchen towels, toilet rolls which,
    48        to my knowledge, are 100 per cent recycled, they come from
    49        the supplier here in the UK, but we do not deal with them;
    50        we do not deal with that type of product.  I know tray 
    51        mats ---- 
    52 
    53   MR. JUSTICE BELL:  Leave it there.  It sounds as if you cannot
    54        help any further on the overall figure.
    55        A.  No, I cannot.  As I said, most the items that he
    56        mentions are recycled, so I do not know whether the virgin
    57        figure would going become a lot bigger, but part of the
    58        happy meal do contain -- the happy meal containers are made
    59        of top colour, so they do contain or would have in 1992 if
    60        that is the still figure they were based on, they would

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