Day 006 - 05 Jul 94 - Page 14

     
     1        normally four or five supervisors.  It is rather a
              pyramid.  Paul and Nigel would have been operations
     2        managers or market managers charged with the overall
              operations, responsible for their part of the region.
     3
         Q.   And Peter?
     4        A.  Peter would have been the regionable manager --
              assuming this is Peter Richard, I would guess it is.
     5
         Q.   So, it is all within the region?
     6        A.  All within the region, although Peter, as an officer
              of the company, would have a more direct relationship with
     7        the rest of the McDonald's operated restaurants than the
              other people.
     8
         MR. MORRIS:  So Peter is the top person mentioned on this memo?
     9        A.  Well, assuming it is Peter Richards, yes.  I cannot be
              a thousand per cent sure but, given the order of which
    10        they have shown the names, I would surmise that is Peter
              Richard.
    11
         Q.   Who was Frank Frost?
    12        A.  Frank Frost is equipment manager, I believe.
 
    13   Q.   Nationally or regionally?
              A.  No, regionally.
    14
         Q.   Do any of those people attend national meetings?
    15        A.  I would imagine they do.  I could not tell you exactly
              which one or when, but I would imagine they attend
    16        meetings of their peers.
 
    17   Q.   So do you know if this important matter was brought up at
              any national meetings?
    18        A.  I do not myself, no.
 
    19   Q.   But Andrew Taylor would know, would he?
              A.  Whether the matter discussed on this February 1992
    20        memo was brought up nationally?
 
    Q.   Yes.
              A.  He or Peter Richard may very well know, yes.  I am not
    22        sure. Frank Frost himself might know, but I am certainly
              not aware one way or the other whether it was discussed at
    23        a national meeting. I do not know.
 
    24   Q.   If we go to the incident itself?
              A.  Yes, am I looking for another document?
    25
         Q.   Yes.  Are you familiar with the causes of this death? 
    26        A.  Electrical shock, yes. 
  
    27   Q.   Have you looked into the general situation that this death
              occurred in?
    28        A.  I know that it is a very tragic accident.  We all
              regret it terribly.  I also know that a young man, who had
    29        been party to extensive training, knowledge of what you do
              and what you do not do, chose for whatever reason to not
    30        follow the published procedure.  It is a shame we cannot
              bring him back.