Day 140 - 22 Jun 95 - Page 24

     
     1        get into a debate, in a general sense, as to what is
     2        suburbs and what is not.  What we tried to do, out of
     3        fairness, is choose what they chose, the geographical area
     4        that they chose.
     5
     6   Q.   I am obviously not making myself clear.  When you gave the
     7        figure of 200 for the Philadelphia region, was that the
     8        same area as they chose or a larger one?
     9        A.  No.  That is that third area I was mentioning, my Lord.
    10
    11   Q.   How many McDonald's in the area which they chose?
    12        A.  That would be 118, my Lord.
    13
    14   MS. STEEL:  Can you just tell us which of the ones in the
    15        suburbs was 24 miles out?
    16        A.  They all are.
    17
    18   Q.   All of them?
    19        A.  Yes.  Well, the furthest any of them are is 24 miles.
    20
    Q.   Yes.  Which one is the one that is 24 miles out?
    22        A.  Oh God, I would have to get a map of Philadelphia.
    23        I do not know Philadelphia -- I know Philadelphia well, but
    24        not that well.  The way I would have done it is taken a
    25        map.
    26
    27   Q.   So how many McDonald's stores were there in the actual city
    28        centre at that time?
    29        A.  I believe it was 43.
    30
    31   Q.   And that was including?
    32        A.  When you say "city centre", you are talking about the
    33        entire city, because there is a place called Centre City
    34        within the city.
    35
    36   Q.   Right.  The entire city.
    37        A.  OK.  I believe it was 44.
    38
    39   Q.   That would include the regions listed here as
    40        South Philadelphia, North Philadelphia, West Philadelphia
         Kensington, Oaklane -----
    42        A.  Wait a minute, wait a minute, hold on a second. (Pause)
    43        I believe so.
    44
    45   Q.   The other two areas would be Omney and Mountsair, would it?
    46        A.  This goes back a long time.  I remember that there were
    47        33 stores in their entire survey.  That included, my
    48        recollection is, both city and suburban; and where the
    49        break point is between city and suburb, at this point,
    50        I cannot tell you. 
    51 
    52   MS. STEEL:  It is something of a grey area in your mind? 
    53        A.  No.  I do not recall where they broke it, if you will.
    54
    55   Q.   They list the places?
    56        A.  But they just list them continuously.
    57
    58   Q.   Sorry, I did not understand what you meant by that.
    59        A.  They do not really designate what they are doing here,
    60        so I cannot say for certain what they were doing.