Confirms that he is a Vice President and Associate General Counsel of McDonald's. Refers to 3 incidents: one of a McDonald's employee passing typhoid onto customers, an outbreak of E-coli food-poisoning and an incident where a customer found a foreign object in a McDonald's product.

Vice President and Associate General Counsel of McDonald's Corporation

1. I am an a Vice President and Associate General Counsel of McDonald's Corporation and have personal knowledge of the matters contained within this statement.

2. In 1987 the local Health Department found that an employee of a McDonald's restaurant in Silver Spring, Maryland, who was, unknown to the management of that McDonald's restaurant, a passive carrier of typhoid prepared shrimp salad which caused the customers who consumed them to contract typhoid. McDonald's paid the medical bills and related claims of these customers because, among other things, strict liability would apply to any claims made under Maryland law, even without a finding of negligence. McDonald's also provided treatment, at its own expense, for the employee over a several month period.

3. In 1982 approximately 47 people, mostly in Michigan and Oregon, not all of whom had eaten at McDonald's, were found to be infected with a previously unknown strain of E. Coli. The Center for Disease Control (CDC) performed a statistical analysis of the outbreak and concluded that its research inferred a numerical correlation between the outbreak and McDonald's. McDonald's paid the medical bills and related claims of these individuals as a means of settling the matter to everyone's satisfaction. There was never an admission of liability on McDonald's part.

4. I have read the allegation concerning the claim made by Jeremy Schneider that he found a foreign object in a sandwich purchased at a McDonald's restaurant. I am aware of the manufacturing processes followed by McDonald's suppliers and it is not possible that the foreign object described by Schneider could have ended up in the meat product which went into the sandwich. Pursuant to McDonald's investigation of the Schneider and his facts McDonald's concluded that the claim was fraudulent. However, based upon circumstances beyond our control, including certain omissions by outside counsel we reluctantly settled the case. There was never an admission of liability on McDonald's part.

exhibits: Not applicable/ available

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