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1. I am Supervisor of the Quality Assurance Department as Perseco, the designer and purchaser of packaging for McDonald's s Restaurants in selective markets worldwide
2. I joined Perseco in September 1991 as an Environment Supervisor before moving to the Quality Assurance Department in April 1993, Prior to joining Perseco I had attained a degree in biology from the University of Nijmegen, and an MBA from the University of Rotterdam. As part of my Job, I prepared reports setting out the packaging use by McDonald's in Europe in 1991 and 1992
3. 1991 was the first time such a report had been prepared and it took the form of a brief summary The 1992 report was a far more detailed one. Copies of these reports are annexed hereto at "CVE 1 " and "CVE 2 " respectively and I confirm that the f figures mentioned are correct. I am in the process presently of preparing a report on McDonald's packaging usage in 1993
4. In 1992 McDonald's in Europe consulted 25,033,101 kilograms of paper, paper board and wood in its packaging including transport packaging. Of this 14,885,177 kilograms was made from recycled paper and consequently did not directly require the harvest of any timber. I attach at "CVE: 3. a table I prepared based on the Packaging Material Use McDonald's in Europe 1992 Report confirming the calculation of McDonald's use of virgin fibre.
5. A substantial proportion of the virgin paper used (nearly half) is in respect of the cupstock packaging. The biggest supplier of this is Enso-Gutzeit in Finland. Consequently in estimating the Square milage of timber land which would have bean required to be harvested for McDonald's packaging in 1992 I have used figures supplied to me by Enso-Gutzeit which calculate that 33 hectares of average southern Finnish forest, which is where Enso-Gutzeit obtains it wood, has word for 1000 tons of paper boared. I attach st "CVE 4" a copy or the letter from Enso-Gutzeit , together with a copy of the Annual Ring produced by the Finland Forestry Commission upon which the letter was based.
6. From these facts it can be calculated tat the amount of packaging consumed by McDonald a would require approximately 335 hectares of timberland (10,148 tons x 33 hectares). As the 100 hectares is equal to O.3861 square miles, this means that approximately 1.293 square miles of timer land was required for McDonald's packaging in Europe in 1993 .
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Appeared in court
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