Day 061 - 05 Dec 94 - Page 10

     
     1   Q.   Yes.
     2        A.  I asked for verification on the percentage of recycled
     3        material in the paper bag and, as I understand it, this is
     4        what came back.
     5
     6   Q.   Right.  But you did not see it until this morning?
     7        A.  No, and I have not read the documents either.
     8
     9   Q.   You see, if we turn to the documents that you have
    10        disclosed or that McDonald's has disclosed in relation to
    11        this issue, it is starting at document No. 25 in that
    12        bundle?
    13        A.  I do not seem to have a 25.  My file goes from 22 to 26
    14        and nothing in between.
    15
    16   MR. JUSTICE BELL:  There should be one sheet, a letter dated 7th
    17        July 1989?
    18        A.  Is this from Fort Stirling?  Yes, I have that.
    19
    20   MS. STEEL:  This is a letter stating that from 31st July your
         kitchen towels and toilet paper will be made from recycled
    22        paper?
    23        A.  Yes.
    24
    25   Q.   And the following document, document No. 26?
    26        A.  That is Karran Products?
    27
    28   Q.   Yes, that is right.  This is happy hats.
    29        A.  Yes, and birthday hats.
    30
    31   Q.   Do you note that the third paragraph says:  "We will start
    32        using recycled paper when our present stock is depleted"?
    33        A.  Yes.
    34
    35   Q.   "But, meantime, we will draw up and submit for your
    36        approval the recycled logo and wording".  So, it was some
    37        time after October 1990 that you started using recycled
    38        paper in happy hats?
    39        A.  It says:  "The first deliveries of the new contract
    40        will be made week commencing 5th November", so, yes.
    41
    42   Q.   Document 27 from Alex Popper, 3rd June 1991, which says the
    43        company has approved the printed samples on 100 per cent
    44        recycled paper of the place mats?
    45        A.  Yes.
    46
    47   Q.   So, 100 per cent recycled paper was only introduced in the
    48        place mats after June 1991?
    49        A.  Well, I do not think it says that.  It says "you have
    50        approved our printed samples"; it could equally have said 
    51        "you have approved our printed samples on virgin paper". 
    52 
    53   Q.   Number 2 it says:  "We further agreed that to cover the
    54        increased costs of recycled paper" which implies that it
    55        has only just been introduced?
    56        A.  Well, not necessarily.  It may be that recycled paper
    57        increased in cost as did manufacturing and distribution
    58        cost on the next lines.
    59
    60   Q.   What is that paragraph in the middle then:  "We, therefore,