Day 240 - 24 Apr 96 - Page 17

     
     1        Philip?
     2        A.  It is.
     3
     4   Q.   Right.  Can you confirm that what I have read out as your
     5        evidence has your signature at the bottom, yes?
     6        A.  It is, yes.
     7
     8   Q.   Dated 20th March 1995.  Do you stand by that statement as
     9        evidence?
    10        A.  I do.
    11
    12   Q.   I think it is probably appropriate to deal with the letters
    13        at this stage.  I know you have copies up there in the
    14        witness box but we have got them in the bundles.  Which one
    15        of the letters would you like to refer to first?
    16
    17   MS. STEEL:  Perhaps if you did the memo?
    18        A.  I would suggest that we go refer to them in the order
    19        perhaps that they are taken up in my evidence.
    20
    MR. JUSTICE BELL:  What I do not want is for a witness to read
    22        through documentation which is part of the case.  On the
    23        other hand, what I am anxious is that I should not omit to
    24        read myself one of the documents, so what I really would
    25        like you to do is draw my attention to just where they are
    26        and I can cast my mind over them.  Some of them are ones
    27        which are referred to, particularly in passages which have
    28        been edited out of Mr. Secrett's statement, are familiar to
    29        me anyway.
    30
    31   MS. STEEL:  Perhaps the easiest way is in pink volume 16.
    32
    33   MR. MORRIS:  This is the memo of Annette Allen.
    34
    35   MR. RAMPTON:  Tab 5, my Lord.
    36
    37   MR. JUSTICE BELL:  Yes.  Do you want me to read that through to
    38        myself now or later.
    39
    40   MS. STEEL: If you open it up at tab 5, was there something in
         particular in the memo that you wanted to draw our
    42        attention to and refer to?
    43        A.  I think within the context ----
    44
    45   MR. JUSTICE BELL:  Let me just read it through, please (Pause).
    46        What were you going to say, Mr. Secrett?
    47        A.  I think specifically in relation to this memo, which
    48        refers to some of the conversation that we had during our
    49        meeting, that it is significant, in my view, that
    50        Annette Allen in this internal memo recognises that other 
    51        competitor hamburger chains have publicly admitted that 
    52        they use South American beef and have said, one of them at 
    53        least, that, and I quote, "any hamburger chain denying
    54        using such meat is lying".
    55
    56        This paragraph goes to the heart of the conversations and
    57        correspondence that I had with McDonald's representatives
    58        because our contention is that because of the way, as
    59        I have made clear in my statement, the health certification
    60        and labelling system operated by the US Department of