Day 163 - 25 Sep 95 - Page 18

     
     1        have been cited for any kind of violation, would not
     2        destroy that information.  I have a reasonable belief that
     3        that information is available from McDonald's.
     4
     5   MR. JUSTICE BELL:  What information is there going to be, what
     6        evidence is there going to be?
     7
     8   MR. MORRIS:  Other documentation, or it could be done in
     9        interrogatory form, or just a simple admission really.  We
    10        do not necessarily want unnecessary documentation if a
    11        simple admission would save time and effort, then that is
    12        easier.  Shall I try to go quickly through the list?
    13
    14   MR. JUSTICE BELL:  Yes.
    15
    16   MR. MORRIS:  The next one is on page 2.  There is a reference to
    17         -- this from the New York Times, February 21st, the
    18        violations, McDonald's 65 East 161st Street.  Then on
    19        page 4 of the document in the centre of the page there is
    20        another reference to McDonald's 65 East 161st Street,
          "Mouse droppings, basement shelves littered and broken,
    22        roaches, no protection certificate."   That was on
    23        January 10th, 1988, that that was reported.  Those
    24        violations are reported under the heading of "Violations".
    25
    26        To some extent, obviously, it would have been helpful to
    27        have the complete document, but I do not think it is
    28        necessary to have hundreds of pages just to deal with the
    29        ones that are relevant to McDonald's.
    30
    31   MR. JUSTICE BELL:  Why do you say it would be helpful to have
    32        the whole document?  Do you mean the whole printout?
    33
    34   MR. MORRIS:  Yes, if I had the whole printout it would not be so
    35        difficult.
    36
    37   MR. JUSTICE BELL:  But would it have any more information than
    38        I have got in relation to the ones you want to amend in
    39        respect of?
    40
    MR. MORRIS:  No.  Sometimes it is little bit hard to follow
    42        though, because it says 21 companies cited, then there is
    43        dot, dot, dot, and then it comes down to McDonald's.  So it
    44        does require a little bit of reading between the lines and
    45        cross-referencing.  So that is 65 East 161st Street,
    46        New York.
    47
    48        The next one in this document -- I am trying to go through
    49        the order that it is actually in the document.
    50 
    51   MR. JUSTICE BELL:  It would help me if you can go in the order 
    52        on your sheet --- 
    53
    54   MR. MORRIS:  Yes.
    55
    56   MR. JUSTICE BELL:  -- because I have numbered them.
    57
    58   MR. MORRIS:  OK.
    59
    60   MR. JUSTICE BELL:  So try Jerome Avenue.