Day 060 - 02 Dec 94 - Page 50


     
     1   Q.   Where did you get the figures from for that?
     2        A.  From the supplier and Perseco.
     3
     4   Q.   In what form -- in a letter?
     5        A.  Again, generally, in a meeting.  We go on to say there
     6        we used a higher percentage of recycled papers bags prior
     7        to that time.  My recollection was it was close to 50 per
     8        cent originally.  We asked the supplier to try to increase
     9        the recycled content in the paper bag.  He said he did not
    10        feel the bag would be strong enough to carry the products
    11        inside of it, but after some trials he found it was.  So,
    12        it was on our instruction that they went to 100 per cent.
    13
    14   Q.   That is what he said?
    15        A.  Pardon?
    16
    17   Q.   That is what the supplier said, was it?
    18        A.  No, it was our instruction that they went to 100 per
    19        cent.
    20
    21   Q.   Did you find out whether they actually did that?
    22        A.  Yes.
    23
    24   Q.   They said they did?
    25        A.  They say they have and they say that currently and
    26        since 1991 all the bags have been 100 per cent recycled
    27        paper, unbleached.
    28
    29   Q.   Can you turn to the Defendants' supplementary list of
    30        documents, No 7.  It will be kingfisher blue.  It will not
    31        be the first list; it will be the supplementary list.
    32
    33   MR. JUSTICE BELL:  Which bundle do you want?
    34
    35   MS. STEEL:  We do not have them down here.
    36
    37   MR. JUSTICE BELL:  Do you have a number of the document?
    38
    39   MS. STEEL:  It is supplementary list, documents No. 7.
    40
    41   MR. MORRIS:  It is probably bundle 1.
    42
    43   MS. STEEL:   It is the Fact Book.  This document was disclosed
    44        by us, but perhaps you can confirm that it is a McDonald's
    45        document?
    46        A.  No. 7?
    47
    48   Q.   Yes.
    49        A.  Yes, it is.
    50 
    51   Q.   If you can turn to page 34? 
    52        A.  I do not think I have any numbers; it is all blanked 
    53        out.
    54
    55   Q.   The bottom corner should have numbers in?
    56        A.  It does not; it is just a blank.
    57
    58   Q.   Before you get to the black part, the bottom of the white
    59        corner.  Some of them are in the left-hand corner and some
    60        of them are in the right-hand corner.

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