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

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