Day 080 - 30 Jan 95 - Page 47

     
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     2   MR. JUSTICE BELL:  Have you got that?
     3
     4   THE WITNESS:  I have volume XI, sir, yellow.
     5
     6   Q.   Right at the very back, tab 5, right at the back, not the
     7        one about halfway through.
     8        A.  Yes, I have it.
     9
    10   MR. MORRIS:  You said it seemed to be a US document.
    11        A.  The one that is headed:  "Specification for Frozen
    12        Quarter Pounder Meat Patties, England"?
    13
    14   Q.   Yes.  Have you ever seen this document before?
    15        A.  Yes, I think so.
    16
    17   Q.   What was the difference between this and the USA?  How did
    18        you treat this document when you got it sent from America,
    19        or wherever it was -- was it sent from America to you?
    20        A.  It would have come, I think I said previously, it would
         have come via Keystone Foods who were partners in the
    22        company at that time.
    23
    24   Q.   So was it something that was binding upon the UK or was it
    25        just something to show what was happening in America?
    26        A.  No, it was something which was sent over in order that
    27        we could set up standards in the United Kingdom and supply
    28        beef burger in the United Kingdom to the same
    29        specifications as those in the United States of America.
    30
    31   Q.   So did you draft up a specifically UK specifications
    32        document?
    33        A.  Yes, I am sure we did.
    34
    35   Q.   We have not seen one of those, have we, apart from the
    36        suppliers' specifications that you got from October 1991?
    37        A.  No.
    38
    39   Q.   Have you got similar ones to that 1991 going back?
    40        A.  All the specifications on the actual burgers have come
         from McDonald's.  This document originally came from
    42        McDonald's and subsequently ones would come from
    43        McDonald's.
    44
    45   Q.   What I am trying to say is when can you recall was the
    46        first time that specifically a UK specifications document
    47        was in place, was drafted and on paper?
    48        A.  What, for manufacturing the burgers?
    49
    50   Q.   Yes. 
    51        A.  I would not think ever.  We would have done a meat 
    52        specification document, but not a McDonald's document. 
    53
    54   Q.   I am getting confused.
    55
    56   MR. JUSTICE BELL:  What are you after now, Mr. Morris?
    57
    58   MR. MORRIS:  I am confused at the state of this document because
    59        it contains some things, for example imported beef which he
    60        said did not apply to the UK specification, and therefore