Day 069 - 19 Dec 94 - Page 06

     
     1
     2   Q.   It is the letter from the FOIA.  You do not have that?
     3        A.  No.  (Handed)
     4
     5   Q.   Ignore the letter at the front from Mr. Stafko and turn, if
     6        you will, directly to the first of the documents.
     7        A.  OK.
     8
     9   Q.   Since these documents were produced by the Defendants, have
    10        you had a chance to consider them?
    11        A.  Yes, I have.
    12
    13   Q.   Have you been able to make any enquiries in the
    14        United States about any of the questions of fact to which
    15        these documents may be thought to give rise?  Perhaps
    16        I should be more specific.  Have you been able to speak,
    17        for example, to Tyson Foods about any of the particular
    18        incidents listed in the first few pages?
    19        A.  Yes, I have.
    20
    Q.   Can we then just have a brief look at them?  The first
    22        document, I hope, and there should be a page number in
    23        handwriting at the bottom, page 1 -- do you have that?
    24        A.  Yes, I do.
    25
    26   Q.   The date of this incident, or alleged incident, is
    27        19th December, 1993.  You should see that in a box in the
    28        middle of the page.  Do you see that?
    29        A.  Yes, I do.
    30
    31   Q.   The incident, it seems, arose out of something found in a
    32        McChicken sandwich at a McDonald's in Concord -- what does
    33        "CA" stand for?
    34        A.  California.
    35
    36   Q.   The supplier or the manufacturer of the food item was Tyson
    37        Foods of 100 E. Cassdy, Nashville -- is that Arkansas?
    38        A.  That is correct.
    39
    40   Q.   Does that Tyson's plant at Nashville, Arkansas, manufacture
         products for McDonald's?
    42        A.  Yes, they do.
    43
    44   Q.   Do you understand what the nature of this document is?
    45        A.  Yes, I do.
    46
    47   Q.   Could you tell us, please?
    48        A.  It is a document that is produced by the US government
    49        when they follow any complaints from customers, and they
    50        follow a regular process with a document, what the 
    51        complaint is; they follow up and investigate every single 
    52        complaint that there is, and they come up with an answer. 
    53
    54   Q.   It says in the text, item 7, "nature of complaint and
    55        remarks" -- have you that bit on the front page?
    56        A.  Yes.
    57
    58   Q.   It says that the consumer claimed that his wife choked on a
    59        bone while eating a McDonald's McChicken sandwich, and that
    60        the compliance officer, Velma Campbell, interviewed the