Day 013 - 19 Jul 94 - Page 10

     
     1        a suggestion generally, because sometimes people are
              being evasive but not always.
     2
         MS. STEEL:   I understand.  (To the witness):  If you do not
     3        remember what was discussed at this meeting, can you be
              sure there was not some kind of agreement, you know,
     4        discussed and arranged?
              A.  I suspect if I had an opportunity to go through all
     5        the documentation again, I could perhaps refresh my
              recollection on some specifics, but there is no question
     6        in my mind as to whether an agreement was made or not
              made.  That is something I would clearly remember as it
     7        would be, it would have been the high point of the
              meeting.  It would have been something that would have
     8        survived that meeting and significantly, in my opinion,
              affected McDonald's Corporation.  There was no agreement.
     9
         Q.   Whether or not there was an agreement, do you remember a
    10        discussion or the Attorneys General mentioning that they
              thought it would be a good idea to do a press release to
         inform people of these brochures being made available?
              A.  I do not have that recollection.
    12
         MR. JUSTICE BELL:  I think what is being put to you, you do not
    13        have a recollection -- are you saying positively there was
              not or there may be, but you really just cannot remember?
    14        A.  I have to say to you that I just cannot remember.
 
    15   MS. STEEL:   Thank you.  Do you also say there was no agreement
              of any sort about the provision of booklets aside from the
    16        issue of making the press release?
              A.  There was no agreement of any sort.
    17
         Q.   Right.  So what did you say to them when they said to you:
    18         "We would like these booklets provided"?  What did
              McDonald's say to them?
    19        A.  Well, as I mentioned before, I really cannot remember
              the specifics of the meeting.  At the time of the meeting,
    20        we were already making distribution on the East Coast.
              They were aware of that.  We may well have said to them at
         that time that we were some time in the future planning on
              doing something nationally.
    22
         Q.   Given their concerns, do you think you could have said to
    23        them:  "Well, as you are concerned, we will introduce
              these much sooner in Texas and California"?
    24        A.  I am not sure it would have been in our interests at
              any time to give much more information as to our plans
    25        than was absolutely necessary.  I cannot recall that.  I
              do not think that was said. 
    26 
         MR. JUSTICE BELL:  Might you have brought forward what you say 
    27        that you began to think was a good idea to do anyway --
              might you have brought that forward in time because of the
    28        Attorneys' General of Texas and California interest,
              putting it in absolutely neutral terms?
    29        A.  Might that possibly have been a factor, something that
              was in our minds at the time?  That is possible.  That is
    30        possible, yes.  The fact that they were there; I recall
              that a lot had to do with -- printing these up was no