Day 013 - 19 Jul 94 - Page 04

     
     1        It is a long time ago, but my recollection was that it was
              very informal.
     2
         Q.   Informal?
     3        A.  Yes.
 
     4   Q.   Had you had much contact prior to that phone call?
              A.  Well, there were prior investigations which I am
     5        trying to remember whether it was from Mr. Mandell or from
              the department of law in the state of New York but, as
     6        I believe I mentioned yesterday, I had known Mr. Mandell
              from conversations concerning McDonald's previous to
     7        this.  As I recall also, I had dealt with him from when
              I had been attorney from my prior employer Pan American
     8        airways with respect to their activities, so I knew him
              for a long, long time.
     9
         Q.   There had been a prior dispute, had there not, between
    10        McDonald's and the New York Attorney General's office?
              A.  As I mentioned, there were conversations we had.
         I believe a couple of years earlier we may have had
              conversations concerning -- I believe it had to do with
    12        chicken McNuggetts.
 
    13   Q.   I think that, in fact, was in that the New York Attorney
              General wrote to you in September 1985 just a few months
    14        before, in fact?
              A.  It may have been, I just do not recall.
    15
         Q.   Perhaps we should briefly look at -- if you could get
    16        volume 7E.
 
    17   MR. JUSTICE BELL:  Volume?
 
    18   MS. STEEL:   Pink.
              A.  Pink VII.
    19
         Q.   Yes, tab 24.
    20        A.  OK, I am there.
 
    Q.   Right.  There is a letter from the New York state
              department of law dated September 6th 1985.  They are
    22        writing because the Centre for Science in the Public
              Interest has requested that the New York state Attorney
    23        General office investigate McDonald's advertising of
              chicken McNuggetts?
    24        A.  May I take a second to read that?
 
    25   Q.   I will read it out.  It goes on to say:  "The Centre for
              Science in the Public Interest contends that certain 
    26        statements contained in McDonald's advertisements are 
              false and misleading, specifically CSPI alleges that (1) 
    27        the advertising claim that only delicious chunks of juicy
              breast and thigh meat go into chicken McNuggetts is false
    28        because in fact the chicken meat is mixed with chicken
              skin and McNuggetts are cooked in high fat feed lard which
    29        is absorbed into the chicken.  (2)  The advertising claim
              that McNuggetts are made from whole breasts of thigh is
    30        misleading because it fails to disclose the presence of
              chicken skin and beef fat; (3) The advertising claim that