Day 061 - 05 Dec 94 - Page 07

     
     1   Q.   What do you mean the statement was updated?
     2        A.  Well, my evidence originally was given way before 1993
     3        or the written down evidence, and I was asked to update it
     4        in 1993 for this trial.
     5
     6   Q.   Right.  So you had made a statement for the purposes of
     7        this case prior to this statement which we have in court
     8        today?
     9        A.  Yes.
    10
    11   Q.   You are saying that was made in 1991?
    12        A.  Well, it may have been before that.  It was a long
    13        while ago.
    14
    15   Q.   So you did not check these figures before signing the
    16        statement in 1993?
    17        A.  I asked for them to be checked and I was told that the
    18        numbers given to me originally were correct which is not
    19        now seen to be correct.
    20
    Q.   Right.
    22        A.  On that one figure.
    23
    24   Q.   Is there any reason why we should assume that all the
    25        others are correct?  It appears they are done from people's
    26        memory as well; you do not have any documents to back it
    27        up?
    28        A.  Mr. Van Erp does.
    29
    30   Q.   He has got documents revealing the recycled content of
    31        various packaging items ---
    32        A.  Well, he has ----
    33
    34   Q.   -- when the content was introduced?
    35        A.  He has given you a list of when Perseco became
    36        involved.  Many of these products are not purchased in the
    37        UK.  Therefore, the responsibility for the documentation
    38        would be in the McDonald's office of the country where the
    39        product is produced.
    40
    Q.   So there might be documents in other countries then?
    42        A.  It is possible.
    43
    44   Q.   What steps have you personally taken to get these
    45        documents?
    46        A.  I have not taken steps to get those documents.  It is
    47        not the responsibility of the UK Purchasing Department.
    48
    49   Q.   You are the witness who is coming to court to give evidence
    50        on this issue and you have asserted in your statement and 
    51        in your evidence in court that you were using these 
    52        quantities of recycled paper in your packaging at the 
    53        various dates given.  So, is it not your responsibility to
    54        get the documents to back that up?
    55
    56   MR. JUSTICE BELL:  "No" is the answer to that.
    57        A.  I do not think so.
    58
    59   MR. JUSTICE BELL:  At the end of the day he is a witness; if he
    60        takes the responsibility for it, then obviously it is.  But