Day 246 - 09 May 96 - Page 05


     
     1   Q.   Right.  If you then turn over to page 2, can you just tell
     2        us who Scope Communications Management are and what they
     3        have to do with McDonald's?
     4        A.  They are a company we retain for public relations
     5        purposes, for advice and consultation on public relations
     6        exercises or programmes we want to put together.
     7
     8   Q.   So that is separate, is it, to Welbeck Golan Harris?
     9        A.  They are two separate organisations, yes.
    10
    11   Q.   They are basically the same thing but you have just got two
    12        of them there, or are they different?
    13        A.  Well, I think one is quite a bit bigger than the
    14        other:  one is multi-national, covers the world in terms of
    15        their offices.  Scope International are really quite small
    16        and located here.
    17
    18   Q.   Right, so it is Welbeck that covers the world?
    19        A.  They are the bigger one, yes.  They would be the one
    20        involved on a global basis.
    21
    22   Q.   OK.  Were Scope somebody you have been employing for quite
    23        some time or were they brought in specifically to deal with
    24        this case?
    25        A.  Scope have been employed by us for, let us say, 3 or 4
    26        years, but not for this case specifically, no.
    27
    28   Q.   Right.  OK.  On the second page, this is dated 31st January
    29        1994?
    30        A.  Yes.
    31
    32   Q.   The subject is London Greenpeace.  We do not know who this
    33        is to or from, but the message is:  "For your comments and
    34        discussions at tomorrow's meeting".  Did you attend the
    35        meeting on what would have been 1st February, 1994?
    36        A.  I do not think so.
    37
    38   Q.   You do not think so.  Do you know whether the page that is
    39        following is part of the same document or is something
    40        separate?  It does not appear to have a date on it so...
    41        A.  No, I do not know.  It would be sort of -- it looks
    42        like it follows on, but I do not know if it is the same one
    43        or not.
    44
    45   Q.   Right.  No 1 is about an internal briefing document for
    46        senior management to answer employees' questions:  "Why are
    47        we bringing this case?"  Do you know whether that was
    48        prepared?
    49        A.  I do not know for sure.  I would guess there was one
    50        prepared, but I am not sure. 
    51 
    52   Q.   Right.  The No. 2, simple briefing sheet for every 
    53        employee; do you know whether that was done?
    54        A.  I do not know.
    55
    56   Q.   No 4 is a detailed briefing paper covering each of the
    57        points covered by the libel action for use in response to
    58        detailed media enquiries.  We have seen the media press
    59        releases that you sent out to various media organisations
    60        when we were looking at them on Tuesday.  They did not

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