Day 013 - 19 Jul 94 - Page 03


     
     1
         Q.   I do not know whether you could check when you go back to
     2        the States whether or not there were any brochures with
              ingredients in prior to the "Food - the Facts" booklet?
     3        A.  I will pass that on to my attorneys.  I am not in a
              position to do that since I am on sabbatical and will not
     4        be returning to work until September.  At that point I do
              not go back in the legal department, I go into operational
     5        training, so I will not be near the headquarters to do
              that, but I will pass your comments on.
     6
         Q.   If customers had rung up this hot line, would they be told
     7        all the ingredients of a particular product?
              A.  They would have, if a customer had indicated that
     8        there was a need for it, for all the ingredients,
              I believe the answer is yes, but more in a customary call,
     9        from what I was told, was that people would call up and
              say:  "I have an allergy to MSG" -- I am making that up --
    10         "can you tell me the foods this is in?"
 
    11   Q.   Are you aware of anyone ever getting all the ingredients
              for particular products?
    12        A.  I am not personally aware of that, no.
 
    13   Q.   As a matter of interest, is this Hazleton laboratories
              report still available?
    14        A.  Do you mean our reports from Hazleton laboratories?
 
    15   Q.   This one in particular?
              A.  I have seen with my own eyes updated Hazleton reports
    16        within the last year.
 
    17   Q.   Right.  Do you know whether the company would have another
              copy of this one here?
    18        A.  If I would guess, I would guess yes, although I am not
              in a position to know.
    19
         Q.   I am only asking because this copy is pretty illegible; it
    20        would be helpful if the court had a more legible copy,
              that is all?
    21        A.  I will pass that request on to our lawyers.
 
    22   Q.   Thank you.  I just wanted to go back to something you were
              saying yesterday:  You were talking about the New York
    23        Attorney General getting in contact with you about these
              ingredients brochure?
    24        A.  Yes, the one we distributed in 1986 are we talking
              about now?
    25
         Q.   Yes. 
    26        A.  Yes. 
  
    27   Q.   Did you say you think the original contact you had was
              with Sandy Mandell?  He just rang up for a general chat?
    28        A.  Well, Sandy Mandell was the primary contact.  He was
              the person that in most instances we dealt with -- I dealt
    29        with.  There were occasions after discussions pursued
              where we had discussions with other people, subordinates,
    30        other people in his office, but I believe the initial
              contact came from him, and I believe it was by telephone.

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