Day 140 - 22 Jun 95 - Page 30


     
     1   MS. STEEL:  She says in the second paragraph: "We are in the
     2        process of reviewing the executive summary of your study
     3        and will be submitting to your our responses and question
     4        several of the shareholders who have contacted me.  I
     5        believe we cannot make a valid judgment about the Company's
     6        report without seeing it."
     7        A.  That is correct.
     8
     9   Q.  "Therefore I request again that you permit the full study to
    10        be reviewed by even a few of us with the agreement that it
    11        will not be submitted to either the campaign or the media."
    12        A.  That is correct.  I think I just mentioned to you that
    13        I had met with Sister Marie-Lucy; I did not have the
    14        complete study at that time; and, subsequently, I offered
    15        it up to her as a result of her request that she would like
    16        to see more.
    17
    18   Q.   Why did you not have a copy of this full study at the time?
    19        Do you mean you had not seen it before that time?
    20        A.  My recollection is that we had the complete study.
    21        I think we had the complete study.  I am trying to
    22        remember.  I am almost positive we did; yes, I am sure we
    23        did.  She asked for a great deal of information beyond the
    24        study as well.  We had approximately a three/four hour
    25        meeting to go over everything that I had brought with me on
    26        that occasion; and they indicated they wanted to think
    27        about what they had heard, what they had seen, and they
    28        would get back to me for additional information.
    29
    30   Q.   So you did have the complete study at the time?
    31        A.  I am pretty sure I did, sure.
    32
    33   Q.   Why did you not give her a copy?
    34        A.  Because I did not think she was interested in the
    35        complete item, that the summaries would be sufficient, and
    36        if they had any specific questions beyond that, I would be
    37        delighted to deal with that.
    38
    39   Q.   It says here: "I request again that you permit the full
    40        study to be reviewed."  It does not sound like she did not
    41        want a copy of it?
    42        A.  As I said to you, she requested to have more
    43        information, and this was her letter following up, asking
    44        for it.
    45
    46   Q.   Why did not you give these community groups a full copy of
    47        the -----
    48
    49   MR. JUSTICE BELL:  I have not yet been told -- or I may have
    50        been and, if so, I have already forgotten it -- what 
    51        happened when you offered her the full report. 
    52        A.  She ----- 
    53
    54   MR. JUSTICE STEEL:   Let us get the facts, as Mr. Stein says
    55        they are; and then you can challenge them if you think they
    56        are wrong.
    57
    58   THE WITNESS:   Subsequent to the letter, she and I had two or
    59        three conversations by 'phone, and I answered various
    60        questions that she raised and offered to hold another

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