Marler Clark attorney, Bill Marler's presentation to ConAgra about the importance of maintaining high food safety standards in food production.

2. 2

9. Litigation as Incentive Jack in the Box Odwalla

18. What ConAgra Should Have Known

19. Establishment Inspection Report February 23, 2005 “ Inspection revealed the following concerns: 2 areas on production lines where filled containers of peanut butter were not completely covered from overhead contamination, an accumulation of spillage and or dust at wall/floor juncture around air handling cabinet in the ingredients room, and a temporary baffle made of cardboard in use on an empty jar line.”

20. “ . . . Inspection found the lot in question had been shipped and management cited corporate policy in refusing to allow review of production and shipping records. The current inspection was conducted in response to several complaints including most recently, number 29134, an anonymous complaint alleging poor sanitation, poor facilities maintenance, and poor quality program management. Specifics in that complaint include an alleged episode of positive findings of Salmonella in peanut butter in October of 2004 that was related to new equipment and that the firm didn’t react to, insects in some equipment, water leaking onto product, & inability to track some product.” Establishment Inspection Report February 23, 2005

21. These complaints include: 29134 dated 1/13/05, an anonymous complaint reporting several issues at the firm that in summary allege poor sanitation practices, poor quality program management and poor facilities maintenance. Establishment Inspection Report February 23, 2005

26. What Will a Jury Think? A Jury = 12 Consumers

27. Questions