Day 195 - 04 Dec 95 - Page 29


     
     1   MR. MORRIS:  I think he has dealt with all those matters then.
     2        I just want to have a quick look at Frank Stanton's.
     3
     4   MR. JUSTICE BELL:  That is divider 4.
     5
     6   MR. MORRIS:  There are a couple of questions on Mark Davis'
     7        supplementary statement.
     8
     9   MR. JUSTICE BELL:  That follows on from 33.
    10
    11   THE WITNESS:  I have it.
    12
    13   MR. MORRIS:  Page 3, his comments on your statement start, but
    14        over the page let us just have a look to see if I need to
    15        ask any questions.  Yes, he says in the middle of his
    16        paragraph 9, just under halfway down:  "The large freezers
    17        in McDonald's restaurants did not and do not in my
    18        experience break down on 'numerous occasions'".  Did you
    19        say they did?
    20        A.  I did not say actually they broke down on numerous
    21        occasions.  I said that meat was defrosted or defrosted
    22        meat was served on numerous occasions and, as an example of
    23        why it should have been defrosted, I gave the break down of
    24        the freezers but there were other examples why meat was
    25        defrosted before cooking.
    26
    27   Q.   In paragraph 10 he says you allege raw meat would be sold;
    28        did you say that?
    29        A.  Yes, raw meat in the middle, not absolutely raw, in the
    30        middle of the quarter pounder.
    31
    32   Q.   Raw in the middle?
    33        A.  Raw in the middle.
    34
    35   Q.   He then says:  "I am sure that I would have known of it;
    36        customers would have complained".  Do you have anything to
    37        say about that?
    38        A.  I mean, generally, Mark Davies claims not to have known
    39        about many things but Mark Davies to me looked as if he was
    40        a Manager who was in charge, in full control of his store,
    41        and he knew what was going on, and he was actually, I can
    42        remember on Saturdays on very busy occasions, when he was
    43        actually packaging the meat.  He was actually not preparing
    44        but putting the meat or the sandwiches in the production
    45        box, if that is what it is called, for serving.  He must
    46        have known and must have felt that the meat was raw in the
    47        middle, and he was actually keeping an eye on who was
    48        cooking it.  So, I assume with his experience he would have
    49        known whether the meat is completely cooked in the middle
    50        or not. 
    51 
    52   Q.   How do you know that the meat he saw was under-cooked? 
    53        A.  Because it was frequently under-cooked.  On busy
    54        occasions you just did not have time when you have one
    55        person on the grill and one person producing quarter
    56        pounders.  You have basically got too much on your hands.
    57        You cannot sear the meat properly and it was frequently raw
    58        in the middle.
    59
    60   Q.   "Customers would have complained", he said.  Any comment on

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