Day 142 - 26 Jun 95 - Page 15

     
     1        A.  Correct.
     2
     3   Q.   And in 1976 Vice President of Individuality, so he is a
     4        high ranking executive, or he was?
     5        A.  He was an Officer of the Corporation.
     6
     7   Q.   Were you interviewed or contacted by the authors of that
     8        book as well?
     9        A.  No, no.
    10
    11   Q.   You were in personnel at the time, were you?
    12        A.  I started in 74.
    13
    14   Q.   When did you become Vice President?
    15        A.  I became an Assistant Vice President in 1978.
    16
    17   Q.   So Jim Kuhn was, in fact, senior to you at that time in the
    18        70s?
    19        A.  He had a higher title, if that is what you are saying.
    20
    Q.   A higher title, yes -- does that not mean senior?
    22        A.  Well, I think you are dealing with an English word and
    23        I am dealing with an American word.
    24
    25   MR. JUSTICE BELL:  Yes.  Were you directly responsible to him in
    26        any way?
    27        A.  No, I was not.
    28
    29   Q.   Or indirectly?
    30        A.  No, my Lord.  I did not report to him in any way.
    31
    32   MR. JUSTICE BELL:  I think that is where the distinction arises.
    33
    34   MR. MORRIS:  Yes.  (To the witness):  Can I just ask you one
    35        further question?  What is Vice President of
    36        Individuality?  What does that mean?
    37        A.  It is a very unique position.
    38
    39   MR. JUSTICE BELL:  It seems to be a contradiction in terms.
    40
    THE WITNESS:  Mr. Khun's responsibility that as we grew larger
    42        was to make sure that the individual did not have any
    43        disadvantages, that while we are getting larger and there
    44        are more people coming on board, his job was to make sure
    45        that individual rights and prerogatives and how they felt
    46        about the Company remained good.  So, he would -- he would
    47        give pep talks and enthusiasm things and things like that.
    48        He was someone who was responsible for keeping up the
    49        spirit and enthusiasm of the Company as we grew larger.
    50 
    51   MR. MORRIS:  What is that, at all levels, or franchisees? 
    52        A.  Oh, yes, especially with regard to that, that would 
    53        really be at the higher levels, if you will, the manager
    54        levels, as well as at the crew level, but at all levels.
    55        He was a very enthusiastic individual and the individual is
    56        very important to McDonald's, and we did something no other
    57        company that I know has ever done, and that is have someone
    58        who looks out for the interests of individuals.
    59
    60   Q.   Can I just ask one legal question?