Day 061 - 05 Dec 94 - Page 17

     
     1
     2   MR. JUSTICE BELL:  It may be a facsimile note of some kind.
     3        A.  I do not know what it means.  We do not have an MG
     4        department, no.
     5
     6   MR. JUSTICE BELL:  It is an American date.
     7
     8   MR. MORRIS:  You have claimed -- sorry, it is an American date?
     9
    10   MR. JUSTICE BELL:  Yes, because the month comes before the date
    11        in the month.  That is on the facsimile note, I mean.
    12
    13   MR. MORRIS:  Yes.  You have claimed that the company is
    14        environmentally responsible; is that correct?
    15        A.  I think we do our best to be.
    16
    17   Q.   And that in a number of documents you have talked about the
    18        improvements of recycled content?
    19        A.  Yes.
    20
    Q.   Over the years?
    22        A.  Yes.
    23
    24   Q.   You have not kept any documents that would prove that
    25        before, well, apart from the ones we have seen; is that
    26        correct?
    27        A.  I have given you my explanation that we were not
    28        required to keep any documents to prove that, and Paul
    29        Edwards himself tends to hoard things and I am not
    30        surprised that those three documents were still in his
    31        files.
    32
    33   Q.   So, having now got yourself into the situation of not
    34        having documentary evidence, would you say that it concerns
    35        you that your department has been so -- would you say that
    36        your department has been irresponsible ---
    37        A.  No.
    38
    39   Q.   -- in making public claims without and keeping documents to
    40        back them up?
         A.  No, I do not think they have.  They may well have had
    42        them.  They do not have them today.
    43
    44   MS. STEEL:  The assertions that you have made about the use of
    45        recycled paper in your evidence, other than those backed up
    46        by documents, are all based on what someone else has told
    47        you; is that right?
    48        A.  Some on experience, some on what somebody else has told
    49        me.
    50 
    51   Q.   So which ones are on experience? 
    52        A.  I personally worked with a lot of these packaging 
    53        suppliers in the early days before Paul Edwards'
    54        employment, for example.  I was involved directly with the
    55        packaging suppliers.  I know them all and I have kept close
    56        contact with them since.  I do visit them from time to
    57        time.
    58
    59   Q.   So what are you talking about, which ones?
    60        A.  Which suppliers?