Day 045 - 03 Nov 94 - Page 28


     
     1        the press releases that went out to the financial
     2        community.  So he may, in fact, have been at some financial
     3        meetings with outside finance people.  But I think the
     4        characterisation there, from my experience, is not
     5        accurate.
     6
     7   Q.   Do you know that he used to accompany President Turner to
     8        important security analyst meetings?
     9        A.  As I said, he did have the role of public relations to
    10        security analysts, and he may, in fact, have gone to a
    11        security analyst meeting with Mr. Turner.  I am not aware
    12        of it, but that would be within the normal course of
    13        things.
    14
    15   MS. STEEL:  When did McDonald's sell its 12 billionth hamburger;
    16        do you know when it was?
    17        A.  No.  I could not tell you when it was.
    18
    19   MR. JUSTICE BELL:  Was it a big media event?
    20        A.  Well, usually----
    21
    22   Q.   Can you remember?
    23        A.  ----at points of time, when we were at 10 billion and
    24        20 billion and 30 billion.  I do not remember 12 as being a
    25        specific event.
    26
    27   MS. STEEL:  Do you remember whether any statistics were prepared
    28        by Cooper and Golin to say how the total of 12 billion
    29        hamburgers stacked in one pile would form a pyramid 782
    30        times larger than that of Snefra----
    31        A.  Larger than that of what?
    32
    33   Q.   Snefra?
    34        A.  It is a reference, I think, to an Egyptian pyramid.
    35        I know there have been times when Golin and others have
    36        tried to put together some statistics like that, of how
    37        many hamburgers would stretch-----
    38
    39   MR. JUSTICE BELL:  It is a purely mathematical calculation?
    40        A.  Yes; how many times it might stretch around going to
    41        the moon and back; very fanciful, but sometimes public
    42        relations agencies have fun doing that.
    43
    44   MS. STEEL:  I do not know whether you have maybe heard of this
    45        one:  "Greater London was the area required to accommodate
    46        all the cattle standing flank to flank that had gone into
    47        the making of the 12 billion burgers"?
    48        A.  No, I do not remember that one.
    49
    50   Q.   You have not heard of that one.  You know that he uses 
    51        these kind of statistics, anyway? 
    52        A.  Yes.  I have seen a number of uses of statistics of how 
    53        many hamburgers McDonald's has sold or how many soft drinks
    54        McDonald's has sold.
    55
    56   Q.   That was kind of issued as, what, like a news release, or
    57        something like that?
    58        A.  Yes, on a public relations basis, it seems to get
    59        picked up by the media.
    60

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