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"?