Day 140 - 22 Jun 95 - Page 11

     
     1        position, if you read the first paragraph, he says -----
     2
     3   MR. JUSTICE BELL:  It is only two pages.  I suggest you read
     4        quickly through them both.
     5
     6   MR. MORRIS:  Yes, OK. (Pause)
     7        A.  I have never seen this memo before.
     8
     9   Q.   Have you finished reading?
    10        A.  I have read it.
    11
    12   Q.   I want to mention a couple of things to you.  The third
    13        sentence in the first paragraph: "I think the union was
    14        effective in terms of reaching the public with the
    15        information" -- sorry, the first page.
    16        A.  Yes.
    17
    18   Q.   "I think the union was effective" -----
    19        A.  Where are you reading from, please?  OK, second line.
    20
    Q.   Second line, I am sorry.
    22        A.  OK.
    23
    24   Q.   "I think the union was effective in terms of reaching the
    25        public with the information that we do use polygraph tests
    26        in a Gestapo type manner."
    27
    28        Do you know which union particularly he was referring to or
    29        that was involved in this?
    30        A.  You see, this precedes my employment.  Really, from my
    31        own personal knowledge, I cannot tell you.
    32
    33   Q.   OK.  At the bottom of the page, in point 4, it says -- I am
    34        going to read the whole bit from the middle of that
    35        paragraph:
    36
    37        "Most human beings are driven by a sense of guilt about
    38        some matter.  This drive will vary in intensity in the
    39        human being in question.  I believe it is this cause that
    40        rests in the confession."
    41
    42   MR. JUSTICE BELL:  "....results in the 'confession'......"
    43
    44   MR. MORRIS: ".... by crew people" -- I just wanted to emphasise
    45        "crew people -- "before, during and after the polygraph
    46        was given to crimes or misdemeanors which they may or may
    47        not have committed."
    48
    49        You have no reason to doubt that the polygraph tests were
    50        used on crew people? 
    51        A.  When I began my employment at McDonald's, my 
    52        recollection is that they were used own on managers only. 
    53        That is my recollection.
    54
    55   Q.   This is before that new policy was -----
    56        A.  I do not know if it is a new policy or an old policy.
    57        I see what this says, but I can only tell you what my
    58        experience was when I joined the Company.
    59
    60   Q.   But John Cook would certainly be a person that knows about