Day 007 - 06 Jul 94 - Page 10
1
Q. Can you take the yellow spine, bundle 3, which
2 Mrs. Brinley-Codd has put out for you, and turn right to
the back which is tab 4 where you will see -----
3
MR. JUSTICE BELL: Which volume?
4
MR. RAMPTON: Yellow volume 3, my Lord, tab 4. Behind tab 4,
5 Mr. Kouchoukos, you should find a statement which you made
and a second statement immediately behind?
6 A. OK.
7 Q. If you go further on through that section you should find
something called "McDonald's Restaurant, Paper Packaging
8 Environmental Perspective". That should be on page 9?
A. Yes.
9
Q. Then if we go to page 11, we find the text dated December
10 17th 1993 ---
A. OK.
11
Q. -- at the top.
12 A. Yes.
13 Q. I am not going to ask you about the quantity of trees or
about the recycled raw material because we are going to
14 come to that in due course. Turn over, please, to page
12. We see a section entitled: "Buying a Big Mac at
15 McDonald's versus making one at home"?
A. Yes.
16
Q. Does what follow represent, as it were, your conclusions
17 upon the research or analysis you did?
A. Yes, it does.
18
Q. If you turn on further in this section to page 15?
19 A. Yes.
20 Q. Do we find charts and tables reflecting what is written on
that page 12?
21 A. Yes, you do.
22 Q. You did this work with Linda Franson?
A. Yes.
23
Q. She is also a Perseco person?
24 A. She is at Perseco under my employ.
25 Q. She is one of your subordinates?
A. Yes.
26
Q. Is this what you found on page 12: "The last section of
27 this report evaluates the amount of packaging necessary to
ship product and customer packaging from manufacturer to
28 point of consumption. The evaluation investigates primary
packaging - the packaging used to deliver the product
29 directly to the ultimate consumer - secondary packaging -
the packaging used in handling or transporting the product
30 to the sales point - and tertiary packaging - the outer
distribution packaging, in most cases the corrugated
