Day 061 - 05 Dec 94 - Page 11

     
     1        await to hear from you as to the additional copy that would
     2        be required to show this fact on each place mat"?
     3        A.  "The additional copy", I would think it was a piece of
     4        artwork they were waiting for, but I do not know.
     5
     6   Q.   Yes, but "to show this fact"?
     7        A.  What fact?
     8
     9   MR. JUSTICE BELL:  What is being suggested to you is that it
    10        looks as if something was being put on place mats to show
    11        that they were 100 per cent recycled paper.  It is
    12        suggested the inference is that that had to be put on
    13        because they were not 100 per cent recycled before.  Can
    14        you help in relation to that?
    15        A.  No, I cannot.  I do not know what copy they were
    16        talking about.
    17
    18   MS. STEEL:  So?
    19        A.  It could have been as Ms. Steel suggested, it could
    20        have been a number of other things; I really do not know.
    21
    22   MS. STEEL:  You did say in your statement in actual fact that
    23        since July 1991 the place mats have been made from 100 per
    24        cent recycled paper?
    25        A.  Yes, I did.
    26
    27   Q.   So that would be in agreement with what I am putting to
    28        you?
    29        A.  Certainly at the time I was given the facts, that was
    30        correct.
    31
    32   Q.   You do not have any information to suggest that 100 per
    33        cent recycled paper was being used before then or recycled?
    34        A.  No.
    35
    36   Q.   You have not information to suggest that recycled paper was
    37        being used before then?
    38        A.  No, I have not.
    39
    40   Q.   These three documents, I believe, are the sum total of the
         documents that have been supplied in relation to -- in
    42        fact, this one is 1991 anyway -- 1989 and 1990?
    43        A.  That is what I am told, yes.
    44
    45   Q.   The recycled content of your packaging?
    46        A.  From McDonald's UK, yes.
    47
    48   Q.   So who keeps the records of when recycled paper was
    49        introduced, all the assertions that you have made about
    50        1981 and dates prior to 1989? 
    51        A.  It clearly was not recorded. 
    52 
    53   Q.   It was not?
    54        A.  I do not think there was any requirement to record it,
    55        to be honest with you.
    56
    57   Q.   Right.  So how would anyone know when the recycled content
    58        was introduced?
    59        A.  Only because Paul Edwards has been with McDonald's for
    60        15 years.  He dealt -- he has dealt with the Alex Popper