Day 025 - 16 Sep 94 - Page 61


     
     1        reprehensible that I do not choose to suppose that
     2        McDonald's engage in that -- if Mr. Rampton does, he may,
     3        but I certainly could not.
     4
     5   MR. RAMPTON:  Leaving aside your finer feelings in the
     6        matter  ---
     7        A.  Or coarser, Mr. Rampton.
     8
     9   Q.   -- if I may, are you different, are you not to the
    10        conclusion that, in fact, the nationwide operation must
    11        have been virtually complete by 4th July, if they were
    12        able to write to their own people in the terms they did on
    13        3rd July 1986 at page 187?  It must be so, must it not?
    14        A.  What operation, Mr. Rampton, the brochure?
    15
    16   Q.   The nationwide distribution of brochures?
    17        A.  Were not to be to be ready until August 16th or
    18        thereabouts.
    19
    20   Q.   August 15th.
    21        A.  I stand corrected.  That is about a 40 to 45-day lead
    22        time which would certainly be enough time to cause the
    23        brochures that were already in existence, the one we have
    24        seen dated April 1987, to be printed in greater quantities
    25        and shipped out.  The decisions reflected in the July 3
    26        letter do not require that greater length of time to make
    27        nor to implement, given that the brochure was already in
    28        existence.
    29
    30   Q.   Have a look at page 194?
    31        A.  Yes, sir, I have it.
    32
    33   Q.   By July 30th, which is 27 days after July 3rd, I think,
    34        they tell you they have already instituted the programme
    35        in New York, Connecticut, New Jersey and the District of
    36        Columbia; that you already knew from their early letter of
    37        21st July.  By this time they have managed to add two
    38        states, the states of Maryland and Virginia.  Do you have
    39        any idea of the planning, the cost and preparation time
    40        required in producing a hundred brochures per restaurant
    41        throughout the country?
    42        A.  Yes, sir.  I am not saying it would be a piece of
    43        cake, but I am saying for a company of the resources,
    44        clout, finances and will of McDonald's, it could certainly
    45        be done in that length of time.
    46
    47   Q.   One final thing, Mr. Gardner:  I think you told us
    48        yesterday that there was -- you started by calling it
    49        "agreement" or maybe they were the words of Mr. Morris or
    50        Ms. Steel, but what it came to was this, that there was 
    51        some kind of informal understanding between you and 
    52        McDonald's and the other companies concerned that there 
    53        would be some kind of joint press release or announcement
    54        of this nationwide campaign.  Is that right?  Have
    55        I understood that correctly?
    56        A.  If you understand the qualifiers, that that is purely
    57        working on memory you have, sir, that is my recollection.
    58
    59   Q.   What I am asking you is this, I think:  How informal was
    60        this understanding to your recollection?

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