Day 046 - 04 Nov 94 - Page 30


     
     1
     2   MR. MORRIS:  November 20th, 1986.
     3
     4   MR. JUSTICE BELL:  There we are.  Six days before this; the week
     5        before.
     6
     7   MR. MORRIS:  (To the witness)  So you may have been reviewing
     8        some of the advice you had been given about the content?
     9        A.  Yes.  These ads had been in development for a number of
    10        months.  You can tell from some of the documents that we
    11        had been thinking about this for a period of time.  So we
    12        would have gone through a process where the people who were
    13        writing the ads would have met with the experts, so that
    14        they understood the topic and could write the ads
    15        accurately.
    16
    17   Q.   So, really, this actual meeting would have been a kind of
    18        pre-launch -- not a pre-launch.  Would it have been a sort
    19        of taking stock, before you launched the actual big
    20        campaign?
    21        A.  Yes.
    22
    23   Q.   Come the following months?
    24        A.  Again, I do not remember the exact meeting, but I think
    25        that would be an appropriate description.
    26
    27   MR. MORRIS:   I do not want to get too bogged down in that, but
    28        maybe we should look at the campaign itself.  If we go to
    29        the actual ads themselves on page 98.  You may have the
    30        originals, I do not know.
    31
    32   MR. JUSTICE BELL:  It is the Time Magazine in front of you.
    33        A.  Yes, I have it.  I have both a copy and the original.
    34
    35   MR. MORRIS:  I have it starting at page 98.  Maybe it would be
    36        useful to start there?
    37        A.  Yes.  That seems to be the cover.
    38
    39   Q.   We did refer to page 101.  You agreed with the introductory
    40        paragraph, if you remember?
    41        A.  Yes.
    42
    43   Q.   This document, which was an internal document -- yes?
    44        A.  Yes, it was.
    45
    46   Q.   Announcing the campaign to your system, yes?
    47        A.  That is correct.
    48
    49   Q.   This would have been something that would have come out of
    50        what you had discussed at that other meeting, or the 
    51        foundations would have been laid at that meeting? 
    52        A.  You mean the words on this page? 
    53
    54   Q.   Not the exact wording, but-----
    55        A.  The context?
    56
    57   Q.   That would have linked, anyway, in some way?
    58        A.  Yes.  We would have a discussion:  "Now that we are
    59        running the campaign, what is the best way to merchandise
    60        the campaign to the system?"

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