Day 013 - 19 Jul 94 - Page 13

     
     1
         MR. JUSTICE BELL:  About nine lines in.
     2        A.  Yes.
 
     3   MS. STEEL:   "We had several telephone conversations with your
              representatives late in June and reported that we would
     4        not be able to spell out the company's plans until after
              the 4th July holiday."
     5
              So, late in June you told the Attorneys General that you
     6        were not going to be able to spell out the company's plans
              until after 4th July holiday.  Was that true?
     7        A.  Let me just a take a moment to read this.  Yes.
 
     8   Q.   That was true?
              A.  Yes, that is my recollection.
     9
         Q.   Right.  Could you look at tab 10, please?
    10        A.  Yes.
 
    Q.   This is a memo dated 3rd July i.e. a day before 4th July
              holiday and 4th July holiday was over a weekend which
    12        would take you as far as 7th July?
              A.  Yes.
    13
         Q.   Right.  So you were, effectively, telling the Attorneys
    14        General that you could not spell out your plans regarding
              the provision of booklets until 7th July?
    15        A.  That is correct.
 
    16   Q.   You have a memo here to all owner operators, all zone
              regional and district managers, all regional operations
    17        and marketing personnel and all officers, dated 3rd July,
              of which the first paragraph says:  "This is to advise you
    18        that on Monday 7th July we will announce to the media that
              ingredient information brochures will be available at all
    19        U.S. McDonald's restaurants, effective 15th August 1986".
              A.  Yes, I have read that.
    20
         Q.   Right.  So on July 3rd, McDonald's was able to tell its
         owners and operators but it was not able to tell the
              Attorneys General?
    22        A.  That is correct.
 
    23   Q.   Why did you say that to the Attorneys General?  Was it to
              give them the impression that you were not going to be
    24        ready until 7th July?
              A.  It is not unusual at all, in my experience, for there
    25        to be great sums of information that we have and may
              discuss internally and distribute amongst ourselves that 
    26        we do not share with people outside of the company until 
              we are good and ready to.  This happens to be one of those 
    27        situations.
 
    28   Q.   This is not just anybody; it is the Attorneys General who
              are concerned about this issue.  Would you not agree it is
    29        fairly clear from that that had you got the pamphlet
              printed in time for the beginning of July -- if you
    30        remember, we looked at the pamphlet which says date of
              print July 1st -- you had issued a press release to the