Day 024 - 15 Sep 94 - Page 16


     
     1   Q.   Right.  So, basically, you were trying to keep things keep
     2        co-operative?
     3        A.  Yes.  As an enforcement matter, when we are dealing
     4        with an entire industry that has problems, we did not
     5        believe that it was wise, efficient and in the public
     6        interest to set about suing individual companies to obtain
     7        the change where a whole industry is, in essence,
     8        violating the law.  We instead, with this industry, with
     9        the fastfood -- with the airline industry, with the
    10        balance of the marketing industry that were marketing
    11        products as environmentally sound, and other areas as well
    12         -- we felt the best mechanism was to educate the
    13        businesses as to our concerns and the ways we felt the law
    14        had been violated, then requesting them to make the
    15        changes.  "Requesting them" may be a soft peddling way of
    16        saying "threatening", but, in essence, we were trying to
    17        engender a co-operative spirit, without saying:  "If you
    18        do not do this, we will sue you".  That specific threat is
    19        not made in this letter.
    20
    21   Q.   But would that have been the position if they had not gone
    22        ahead?
    23        A.  I do not see a choice.  I think if we advise a company
    24        they are violating a law and the company tells us to go
    25        jump in the lake, that, as a matter of enforcement,
    26        necessity and credibility with every company in the
    27        future, we must do that.  We have done that with major
    28        companies.  We sued the Quaker Oats company when Quaker
    29        Oats refused to change its labelling and advertising
    30        practices that linked consumption of oat meal with
    31        production of heart disease, for instance.
    32
    33   Q.   Just one question on the letter:  This is written on your
    34        behalf as well, I think, but it is actually a letter from
    35        the California Department of Justice.  It mentions ten
    36        other states.  Could you just give a bit of background as
    37        to how the other states became involved in this?
    38        A.  It was known at the time by most members of the
    39        industry that the states were working co-operatively in a
    40        multistate ----.
    41
    42   MR. JUSTICE BELL:  May I just ask you, can you remember who
    43        actually drafted the letter dated 6th May 1986 which is
    44        signed by the Attorney Generals themselves of California
    45        and Texas?
    46        A.  In terms of absolute memory, your Lordship, I cannot.
    47        I can tell you how it must have occurred, with the
    48        certainty being 100 per cent that it would have occurred
    49        here.
    50 
    51        As a practice, when two or more states are working 
    52        co-operatively, each of those states under our system have 
    53        actual sovereign interests, have different enforcement
    54        interests.  Any time that a letter went out on behalf of
    55        two states, whether it was signed by one individual, as is
    56        the case with the June 3 letter signed by Mr. Sheldon but
    57        on behalf of the two states, or this letter that is, in
    58        fact, signed by both the Attorneys General of California
    59        and Texas, it would have been written and reviewed by
    60        officials within both offices.

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