Day 062 - 06 Dec 94 - Page 12
1 A. Yes.
2
3 Q. Have you got that fat file? Can you turn right to the end
4 to tab 20? Right at the back of tab 20, it should be the
5 last document in the file at page 489G. You should find a
6 table headed: "Blowing Agent Usage for Sandwich Foam by
7 Country" with a date at the bottom of the page in the
8 right-hand corner, February 3rd 1994?
9 A. Yes.
10
11 Q. You have got that?
12 A. Yes.
13
14 Q. I can tell you (because there is no dispute about it) this
15 was prepared by Mr. David Kouchoukos of your parent
16 company, I suppose, in America?
17 A. Yes, it is.
18
19 Q. Do you know him?
20 A. Yes, I know him very well.
21
22 Q. Really, what I would like your help with, one notices, we
23 have already noticed, that Austria and Germany both use
24 paperboard?
25 A. Yes.
26
27 Q. Do they use any polystyrene foam, the Austrians and the
28 Germans?
29 A. They do not use any polystyrene foam. They use a few
30 -- a few, I should not say -- but they use polystyrene
31 still in lids.
32
33 Q. Lids?
34 A. Lids for cups.
35
36 Q. Do they use any polyethylene?
37 A. Not as part of their sales packaging.
38
39 Q. No. One notices that what one might call the old Soviet
40 bloc countries, that is to say, Czech Republic, Hungary
41 Moscow and Poland, all seem to use wraps?
42 A. Yes.
43
44 Q. Can I ask you, do they make their own wraps or not?
45 A. Partially they do, yes.
46
47 Q. To some extent?
48 A. To some extent they do. It depends a little bit on in
49 some of those countries the import duties or import
50 restrictions are quite high and, therefore, we have looked
51 at the local suppliers. I cannot give you any more detail
52 than that because I have not been personally involved in
53 those type of projects.
54
55 Q. I only wanted a broad picture, Mr. Van Erp. To the extent
56 they do not make their own wraps, where do they get them
57 from, do you know?
58 A. If they do not make their own wraps?
59
60 Q. To the extent that they do not make their own wraps, where
