Day 261 - 12 Jun 96 - Page 12

     
     1        at all the answers which are material to that issue and
     2        make of it what one will.
     3
     4   MR. MORRIS:  (To the witness)  You said that the longer version
     5        of the leaflet was out of stock; sometimes a longer version
     6        of the leaflet was out of stock?
     7        A.  Yes.
     8
     9   Q.   Do you know which version of the longer version of the
    10        leaflet ---
    11        A.  No.
    12
    13   Q.   -- was generally kept?
    14        A.  No, I cannot answer that.
    15
    16   Q.   If kept at all.  How did you identify that it was the
    17        leaflet?  How would you know that there was a pile of
    18        leaflets that were the fact sheets, the leaflets?
    19        A.  The ones that were titled "What's wrong with
    20        McDonald's"?
    21
    22   Q.   Yes.
    23        A.  Yes.  That is because they had the title on them
    24        "What's wrong with McDonald's?"
    25
    26   Q.   Is it because the front cover was unique?
    27        A.  I do not know that it was unique, no.
    28
    29   Q.   Or from the title?  So the short versions, do you remember
    30        they were also called "What's wrong with McDonald's"?
    31        A.  I do not remember now what they looked like, no.
    32
    33   Q.   OK.  So, if you saw a leaflet that had "What's wrong with
    34        McDonald's" on it ---
    35        A.  Yes.
    36
    37   Q.   -- that, as far as you are concerned, is the leaflet
    38        complained of?
    39        A.  I would not know.  As far as I am aware -----
    40
    Q.   When you say "the leaflet complained of", you mean a
    42        leaflet that had "What's wrong with McDonald's" written on
    43        it?
    44        A.  Yes.
    45
    46   Q.   And, you know, which particular version of it, you do not
    47        know?
    48        A.  Not at this length of time, no.
    49
    50   Q.   If it was a long version or a short version, you do not 
    51        know which version of those versions it would have been? 
    52        A.  No.  I would not have had that knowledge. 
    53
    54   MR. JUSTICE BELL:  In the light of this blowing up again -- you
    55        may have done it yesterday, and I just cannot remember --
    56        but if you wished to challenge that there were copies of
    57        the leaflet complained of (because that is what appendix 3
    58        is) on the shelves on one side of the room on 2nd August,
    59        I would like you to do so, merely so I can see whether
    60        there is an issue.