Day 293 - 04 Nov 96 - Page 32


     
     1        statement, which Mr. Mallinson relied on, which we have now
     2        all got copies of hopefully.  Right.  That is my
     3        references.  Bearing all that in mind, can I say actually,
     4        that the second page, the document which I showed that
     5        people could not find, that Mrs. Brinley-Codd had given me,
     6        well that would be page 2 of the one that you handed to me,
     7        Terence Mallinson, the letter from Mr. Thompson, the third
     8        page of it was not there but you had all three pages.  So
     9        what there are in terms of documents are the ones that is
    10        the conversion factors for calculation of forest areas,
    11        then there was the letter to Terence Mallinson from Donald
    12        Thompson that Mr. Mallinson relied on, which is two pages,
    13        and then the second page of what I handed up was a document
    14        which was some kind of trade journal which identified how
    15        much carton board came into the Igessund mill.  That should
    16        be page 2 of that.
    17
    18   MR. JUSTICE BELL:  Yes, I have that.  I am just going to put
    19        that behind the Thompson conversion factors, in turn behind
    20        Mr. Mallinson's November 1994 statement.
    21
    22   MR. MORRIS:   Yes, because if you look at the Igessund's bottom
    23        left-hand box, it shows the raw material intake into
    24        Igessunds.  267,000 cubic metres of small round wood, plus
    25        sawmill soft wood residues, about an extra 10 percent, and
    26        about half of that from the production output is about half
    27        of the total, can you see it, 152,000 tons.  So in reality,
    28        to get 150,000 tons of carton boards, you have to have as
    29        near as makes no difference double the amount at the
    30        beginning.  (Pause)
    31
    32        before I go through my chart I am going to go to the
    33        statement of Mr. Kouchoucos.  It might be helpful to dig
    34        that out, if we can find it.  I don't know where it would
    35        be, actually.  Recycling and waste.  Yellow.  Recycling and
    36        waste witnesses.
    37
    38   MR. JUSTICE BELL:  Well, it is in yellow 3.
    39
    40   MR. MORRIS:   Right.  It is his first statement and it is page 3
    41        of his statement, paragraph 7.  What I have done is, I have
    42        taken his calculation at face value on the grounds that it
    43        is something solid that we can all work on.  And what
    44        I have done is, he says in 1992 McDonald's consumed 180,000
    45        tons of paper, which of course, as we now know, is not the
    46        full figure.  So something should be added on there.  That
    47        would be covered by point 5 of my handwritten ----
    48
    49   MR. JUSTICE BELL:  Yes.
    50 
    51   MR. MORRIS:   In point 5 of my calculations, I am talking about 
    52        you have to add on all the non-Persico packaging, including 
    53        transport packaging for food, office supplies, promotional
    54        material, toilet rolls, kitchen towels, all that kind of
    55        stuff.  Then he says that 51 percent was made from recycled
    56        paper, so that could be discounted.  As we have heard at
    57        the relevant time in this case, the volume of recycled
    58        content was very small and of that recycled content, that
    59        an even smaller part of it was actually post-customer
    60        recycling, even including their calling McDonald's a

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