Day 061 - 05 Dec 94 - Page 18
1
2 Q. No, which products?
3 A. Which packaging suppliers?
4
5 Q. Yes, which packaging?
6 A. Smith Anderson, Benders, Alex Popper. I have visited
7 the German suppliers also but not so frequently which is
8 the -----
9
10 Q. So you personally know all the recycled contents and when
11 they were introduced, are you saying that?
12 A. No, when I was involved with them -- your question was,
13 is all of my evidence based on hearsay, and I am saying,
14 no, it was not.
15
16 Q. I am trying to find out what parts you are asserting are
17 not based on hearsay.
18
19 MR. JUSTICE BELL: Are you just asking about 23 packaging or the
20 whole of the statement?
21
22 MS. STEEL: The packaging at the moment.
23 A. Sorry, what is your question?
24
25 Q. Which of the packaging products do you have personal
26 knowledge about?
27 A. I have just told you.
28
29 Q. No, which products as opposed to which suppliers?
30
31 MR. JUSTICE BELL: Do you actually have your statement?
32 A. I do not have it in front of me, no, my Lord.
33
34 MR. JUSTICE BELL: It is in yellow III at tab 1, page 8.
35 I think what Ms. Steel is asking you, from A through to K,
36 you give dates and figures, percentages, and so on?
37 A. Right.
38
39 Q. I think she is asking you, of all those matters, which ones
40 arise from your personal recollection because of your
41 personal experience at the time?
42 A. OK. (a), (b).
43
44 MS. STEEL: Sorry, (a), the paper bag?
45 A. Yes.
46
47 Q. You are saying that is from your personal recollection now,
48 are you?
49 A. No, I said I do have a personal recollection. I have
50 worked directly with that supplier. It was not hearsay.
51
52 Q. Go on then, carry on.
53 A. (b), (c), (k) and I have visited the suppliers of fry
54 cartons, apple pie cartons and Chicken McNugget cartons.
55
56 Q. Yes. You have visited them, but does that mean you
57 personally ---
58 A. It was not my responsibility.
59
60 Q. -- had knowledge about those figures?
