Day 046 - 04 Nov 94 - Page 37

     
     1        saying is that I cannot tell you right now that they are
     2        exactly the same ads.  I do not have that information.
     3        They well could have been the same ads.
     4
     5   Q.   They do not appear on this list?
     6        A.  That is correct.
     7
     8   Q.   So there must be another list somewhere of when those ads
     9        were run in those magazines and any other magazines that do
    10        not appear on this list?
    11        A.  I am sure there was a list of that.
    12
    13   Q.   Right.  Was there also a list for the thirds and fourth
    14        quarters?
    15        A.  Yes, there would have been.
    16
    17   MR. JUSTICE BELL:  Shall we have our break now?
    18
    19   MR. MORRIS:  Yes.
    20
                        (The Short Adjournment)
    22                                                     2.00 p.m.
    23
    24   MR. MORRIS:  I was just trying to remember where we were.
    25
    26   MR. JUSTICE BELL:  Ms. Steel had asked about the specialist
    27        magazines not being listed, and Mr. Green had said there
    28        would have been a list for the third and fourth quarters
    29        beyond those which are shown on page 183.
    30
    31   MR. MORRIS:  If we go to yellow volume V, Nutrition?
    32        A.  Shall I put this one away?
    33
    34   Q.   I think you can probably close it; it does not matter.
    35        Tab 2 is the statement of Mr. Horwitz.  If we go to behind
    36        his statements, there is a series of adverts.  I have four
    37        adverts at the back of the statement.  Yes?
    38        A.  Yes.  There are several adverts, print advertisements.
    39
    40   Q.   This was 1988, was it not, that it was being claimed that
         these ads, the four at the back, were shown the following
    42        year.  That is the continuation of the campaign?
    43        A.  Yes.  I remember these ads were-----
    44
    45   Q.   Part of the campaign?
    46        A.  -----part of it.  I believe there were others, as well.
    47
    48   Q.   If you look at the letter -- I have not an internal number
    49        here, but the letter from Joanna Hughes?
    50        A.  Client Report 365, on the top? 
    51 
    52   MR. JUSTICE BELL:  Yes, that is right. 
    53
    54   MR. MORRIS:  Yes.  It says: "This reports a conversation between
    55        Joanna Hughes, Thom Kettle and David Green on Tuesday,
    56        December 1 at McDonald's"; yes?
    57        A.  Yes.
    58
    59   Q.   It says, underneath, in the first quarter nutrition
    60        budget: