Day 078 - 26 Jan 95 - Page 64


     
     1   MR. JUSTICE BELL:  Can we just pause there because at the end of
     2        the day you can address me.  You have got that answer.  If
     3        at the end of the day you are going to suggest that the
     4        suffering lasts more than a day, the kind of suffering you
     5        referred to, I think you should put it to the witness.
     6
     7   MS. STEEL:   Right.  The thing is, I did not mean to go down
     8        this line of questioning right now.
     9
    10   MR. JUSTICE BELL:  I am giving you the opportunity to do it.
    11
    12   MS. STEEL:  I will take it up tomorrow but I have not got my
    13        notes prepared on that particular point.
    14
    15   MR. MORRIS:  To finish off the questions on soya feed for
    16        animals, McDonald's have provided a statement from Hans
    17        Schum.  Do you know Hans Schum?
    18        A.  No, I do not know Hans Schum.
    19
    20   Q.   Maybe the Plaintiffs can help me.  I presume he is some
    21        official.
    22
    23   MR. RAMPTON:  My Lord, there two statements from Professor Dr.
    24        Schum: one is at yellow XI 3 and next is at yellow XI 4.
    25
    26   MR. MORRIS:  The first bit is in German.  I have not got the
    27        whole thing here.  Can you find the English bit?
    28        A.  Is the piece headed "Expert Opinion"?
    29
    30   Q.   There are two.  There is one that says "Expert Opinion" and
    31        there is another that is also dated March 28th 1994 which
    32        says "Translation" at the top Sudfleisch.
    33
    34   MR. RAMPTON:  That is tab 4.
    35
    36   MR. MORRIS:  Sorry, that is tab 4.
    37
    38   THE WITNESS:  Yes, I have found that one.
    39
    40   MR. MORRIS:  If you look at paragraph 3 in that, the second
    41        sentence, well, the third sentence says: The Raiffeisen
    42        Concentrated Feed Plant South in Wurzburg use about 3-5 per
    43        cent Argentine soyabean meal and high-yield fodder".
    44        Raiffeisen, that is the feed plant, is it, for Sudfleisch?
    45        A.  I would not know.  I really honestly do not know.
    46
    47   Q.   They are used anyway.  Have you heard of the Raiffeisen
    48        Food Plant?
    49        A.  No, I have not heard of it.
    50 
    51   Q.   Just say, for example, that it is true they are using three 
    52        to five per cent Argentine soybean meal; is that a fairly 
    53        standard percentage for a protein concentrate?
    54        A.  Yes, I would say it was fairly standard, three to five
    55        per cent.
    56
    57   Q.   I am sorry, it is quite a complex statement; some of it is
    58        quite hard to follow.
    59
    60   MR. JUSTICE BELL:  Where do you want to go with this?

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