Day 061 - 05 Dec 94 - Page 08
1 obviously the preparation of McDonald's case has involved a
2 large number of people. He has no legal responsibility for
3 it.
4
5 MS. STEEL: Do you know who took the responsibility of getting
6 documents on this matter?
7 A. I believe Mrs. Brinley-Codd carried out the discovery.
8
9 Q. What, in the company?
10 A. That is my understanding, yes.
11
12 Q. So she trawled around the filing cabinets and the shelves
13 herself?
14 A. I do not know. I do not know what her method was. I
15 would not think so. I would think she asked for the
16 information.
17
18 Q. But you are not aware of who she asked?
19 A. She asked people in the Purchasing Department; Paul
20 Edwards would be one.
21
22 Q. But you were not one of them?
23 A. No, I did not do any trawling of files, no.
24
25 Q. She did not ask you at all about what documents you had
26 available?
27 A. She asked: "Please ask your department to provide any
28 documents available on recycled materials".
29
30 Q. Right. So what did you do?
31 A. I asked the Department Head who in turn carried out the
32 trawl with the relevant buyer which is Paul Edwards.
33
34 Q. If you could get down pink Volume V?
35 A. OK, I have it.
36
37 Q. Turn to tab 41A.
38 A. OK.
39
40 Q. And turn to page 690?
41 A. Right.
42
43 Q. You said that the position in 1991 that you put in your
44 statement was correct; that the recycled content of the
45 carry-out bags was 100 per cent. Then you said that he had
46 so many complaints he had to draw back, withdraw and go
47 back to between 80 and 90 per cent. You implied that that
48 was the position which continued until today.
49 A. Yes, that is what I have been told, yes.
50
51 Q. That is what you were told by Mr. Edwards?
52 A. That is what Mr. Edwards told me at the time I wrote
53 the statement.
54
55 Q. Yes, but you spoke to him sometime over the weekend as
56 well?
57 A. Yes.
58
59 Q. That is what he told you then?
60 A. That the position today is 80 per cent is what he told
