Day 071 - 11 Jan 95 - Page 23

     
     1        to more than is produced in the bundle, having heard what
     2        you want to say and what Mr. Rampton wants to say.
     3
     4                       (Short Adjournment).
     5
     6   MS. STEEL:  We have not got the legal papers with us today, so
     7        we will leave it until tomorrow.
     8
     9   MR. JUSTICE BELL:  You are going to make an application about it
    10        in the morning, are you?
    11
    12   MR. MORRIS:  Yes.
    13
    14   MS. STEEL:  Yes.
    15
    16   MR. RAMPTON:  Can we turn then, please, to page 785, Mr. Stump,
    17        49 of that file.  It is a letter from Andrew Gibson,
    18        McDonald's Market Manager to Mrs. Earle in response to her
    19        letter which we saw earlier.  The third paragraph only I
    20        want to ask you about.  "Mr. Stump has informed me that he
         will have a last environment/index.html">litter patrol carried out late at night to
    22        clear up after any final customers have left the Royal
    23        Avenue.  I do hope this will eliminate this."  When was it
    24        that you stopped having late night environment/index.html">litter patrols?
    25        A.  Approximately two weeks after this letter.
    26
    27   Q.   Did you try it for a time?
    28        A.  We did, yes.
    29
    30   Q.   It was then, was it, that you found reluctance amongst your
    31        staff to do it?
    32        A.  Yes, it was more concern from them about their own
    33        safety.
    34
    35   Q.   Can we turn over then and just note in passing a letter to
    36        Mr. Cantwell who is the Chairman of the Wellington Square
    37        Residents Association to Mr. Cobden; a letter from somebody
    38        called Martin Flash, again I am not going to ask you to
    39        read it in detail, of 36 Royal Avenue on 21st November 1993
    40        saying that the staff did not seem to be doing a very good
         job, so on and so forth, and mentioning that place that
    42        I drew your attention to before where he says in the second
    43        paragraph, third sentence: "One only has to look inside the
    44        railings of Burtons Court to see direct evidence of this",
    45        that is to say, an alleged increase in the volume of
    46        environment/index.html">litter.  He says your clients drop their environment/index.html">litter for up to a
    47        quarter of a mile away from your site for which there is
    48        daily evidence.  Do you know, Mr. Stump, what is the sort
    49        of average distance which the average customer takes to eat
    50        his average take-away McDonald's meal before he is ready to 
    51        dump his environment/index.html">litter on somebody else's property or in the road? 
    52        A.  We believe it is approximately 400 yards. 
    53
    54   Q.   So this would be about right, would it?
    55        A.  Yes.
    56
    57   Q.   Up to a quarter of a mile away.  Then there is a
    58        handwritten letter on the next page 788 from as we can see
    59        at the bottom 789 a Mrs. Geraldine Higson.  I should have
    60        asked you, have you met Mr. Flash or Mrs. Earle or