Day 007 - 06 Jul 94 - Page 24

     
     1        that signified McDonald's.
 
     2   Q.   Its subject is "country by country list of foam blowing
              agents.  Attached is a list of all McDonald's countries
     3        using foam and the blowing agents that are used to make
              that foam.  Only five countries still have foam produced
     4        CFCs, three of them will be changed by the end of the
              year".  First of all, this is written on Perseco paper?
     5        A.  It is.
 
     6   Q.   Is that Perseco's, or one of Perseco's addresses on the
              left-hand side?
     7        A.  That was prior to a subsequent move, yes.
 
     8   Q.   This was while Mr. Langert is still at Perseco?
              A.  It is.
     9
         Q.   So he does not write this as a McDonald's person?  This is
    10        in Perseco's capacity as your predecessor?
              A.  Yes.
    11
         Q.   Do you know what the purpose of this document was?
    12        A.  To monitor our status of CFC phase-out worldwide.
 
    13   Q.   Why was it produced?
              A.  To summarise which countries we may have to be working
    14        with more.
 
    15   Q.   Sorry, that is a very stupid question -- bad question.
              Why did it matter?
    16        A.  Because McDonald's has the environmental consciousness
              that we needed to phase out those blowing agents
    17        worldwide.
 
    18   Q.   I can ask you from your own direct knowledge, did you help
              prepare this document?
    19        A.  I do not think so, not at that stage.
 
    20   Q.   You done the later documents yourself with help,
              I suppose?
         A.  I did.
 
    22   Q.   How do you find out what is going on in each of these
              countries in the world?
    23        A.  Either by phone calls or by fax or in the later
              documents I used to simply send that chart to our Perseco
    24        offices in the other countries.  They would amend the
              chart and send it back to me.
    25
         Q.   In one of the exhibits to your first statement there is 
    26        some correspondence between you and a company called 
              Pacific Cup enquiring about matters of this kind.  Who are 
    27        Pacific Cup?
              A.  The correspondence was with our Perseco Asia Pacific
    28        office.  I am not familiar with the people at Pacific Cup.
 
    29   Q.   What do they do, Pacific Cup?
              A.  Pacific Cup is our phone producer in the Hong Kong
    30        area that supplies many of the countries in that region.