Day 071 - 11 Jan 95 - Page 15


     
     1        find a pink file with V on the back.  It should be called
     2        Recycling and Waste.  Before I ask you to open it (which
     3        will be at tab 49 in a moment), can I ask you this as a
     4        preliminary question before we look at these documents:  In
     5        the 18 months that you have been manager of the Kings Road
     6        restaurant, can you give us a rough idea, first of all, how
     7        many complaints you have had from the local residents or
     8        local residents associations relating to environment/index.html">litter?
     9        A.  Personally, I can remember roughly eight to ten
    10        complaints.
    11
    12   Q.   About eight to ten complaints.  To what extent (and again
    13        only roughly) are those complaints coming from or have
    14        those complaints come from the same person or body of
    15        persons?  Did you get repeat complaints from the same
    16        individual or not?
    17        A.  On one of the occasions the Chairman of the Residents
    18        Association, but he speaks on behalf -----
    19
    20   Q.   He speaks on behalf of the Association.  We will have a
    21        look at the documents now, if you please.  Please turn to
    22        tab 49 which is right at the back, I am afraid.  I do not
    23        know what the first document in your tab is, but it should
    24        look like that.  Yes, that is right.  Can you turn within
    25        that tab to page 779?  Do not worry about the earlier pages
    26        because they all concern matters which arose before your
    27        time.  This, I think, is the first document which relates
    28        to your time in charge in the Kings Road.  It should be,
    29        I hope, a letter from the Royal Hospital Ward of Residents
    30        Association to Mr. Philip Cobden and dated 26th December
    31        1993, is it?
    32        A.  Yes, it is
    33
    34   Q.   He writes at the bottom of this page -- Mr. Philip Cobden
    35        is an Executive Vice-President and Chief Real Estate
    36        Officer of McDonald's in this country -- this is, I remind
    37        you, the end of September 1993.
    38
    39   MR. JUSTICE BELL:  Can you take it very slowly because mine is
    40        feint and I will write it in, Mr. Rampton.
    41
    42   MR. RAMPTON:  I will, my Lord.  It says:  "2.  Litter.  The
    43        regular McDonald's patrol system has broken down and it is
    44        now often stimulated by a resident calling your Kings Road
    45        manager and asking for McDonald's rubbish to be picked
    46        up".  We find -- my Lord, I do not know whether your
    47        Lordship gets better on the next page but I will stop
    48        there.  One question broken down into two, Mr. Stump, about
    49        that:  In September 1993 had the regular McDonald's trash
    50        walk system broken down or not? 
    51        A.  No. 
    52 
    53   Q.   Then, I suppose, the answer to my next question speaks for
    54        itself.  To what extent, if any, were the trash walks at
    55        that time stimulated by a resident calling you and asking
    56        for the McDonald's rubbish to be picked up?  In other
    57        words, to what extent -- this is you personally because you
    58        are the manager at this time -- were you prompted by local
    59        residents to say to somebody in the store:  "Come on, the
    60        trash walk is not being done; go out and do it"?

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