Day 080 - 30 Jan 95 - Page 41

     
     1   Q.   I wanted to ask you about page 55 in this document which is
     2        actually behind tab 5.  If you could turn to that, please?
     3
     4   MR. JUSTICE BELL:  When you say you first saw it last year, you
     5        mean 1994?
     6        A.  Yes, sir.
     7
     8   MS. STEEL:   On page 55 there is a letter from McKey?
     9        A.  It is from the Plant Manager of McKey to one of the
    10        Directors of McKey.  It is an internal memo.
    11
    12   Q.   Andrew Kemp-King, he works for McKeys?
    13        A.  I beg your pardon.  I beg your pardon.  No, it is to
    14        Andy Kemp-King in McDonald's from Adrian Dowling.  I am
    15        sorry.
    16
    17   Q.   Have you seen this before?
    18        A.  Well, I got a copy of it so I must have seen it before.
    19
    20   Q.   You have a copy of it?
         A.  No, I mean, if you look on the back page it says:
    22         "cc. L.D. Walker" but I cannot remember it.
    23
    24   Q.   In the second sentence it says:  "In addition to this there
    25        is very little that I can actually state which will help
    26        you from a PR point of view".  Do you know what that was
    27        about?
    28        A.  No, because it is answering a question, is it not?
    29        "With reference to your enquiry to us concerning animal
    30        welfare issue", there was obviously a specific question in
    31        that enquiry.  So, unless we know what the enquiry was, we
    32        do not know what that means.
    33
    34   Q.   Would you have kept the enquiry, do you think?
    35        A.  I expect Adrian has it in his filing somewhere, yes,
    36        I am sure he has.  1991, yes, I am sure he has.
    37
    38   Q.   So it looks as though at this time they were discussing
    39        developing a policy or developing something to be able to
    40        put out to the public?
    41
    42   MR. RAMPTON:  My Lord, this is a witness of fact.  He cannot
    43        help Ms. Steel or your Lordship in terms of the document.
    44        What he can do is tell Ms. Steel what he recalls of what
    45        was the factual position at the time.
    46
    47   MR. JUSTICE BELL:  Yes.  It is not just a technicality because
    48        it really relates back to what I was saying the other day
    49        about people speculating.  What I suggest is you ask what,
    50        if anything, he recalls about it first of all.  If you want 
    51        to point him in a particular direction, do so. 
    52 
    53   MS. STEEL:   Can you just tell us what you remember about this
    54        document?
    55        A.  I do not remember anything about this particular
    56        document, but I ask you to understand that there are
    57        literally thousands of documents cross my desk in a year.
    58
    59   MR. JUSTICE BELL:  One approach might be to ask Mr. Walker, he
    60        first saw the welfare policy in 1994, does he recall when