Day 069 - 19 Dec 94 - Page 49


     
     1        make addendums to our specifications, to our products.
     2        There are a lot of addendums that have been produced during
     3        this time.
     4
     5   Q.   But this particular one is an international addendum,
     6        applying to all countries; yes?
     7        A.  No.  It is an international addendum that applies to
     8        international countries.  There could be another addendum,
     9        because there are countries that cannot, for whatever
    10        reason -- could be for regulations, because of
    11        availability, for whatever reason it might be, for economic
    12        reasons -- they could not follow our specification.  So, in
    13        that case, they have to make an addendum so we know we can
    14        record some of the changes, so we do not terminate a
    15        supplier because it do something slightly different, and so
    16        we have control over what products and we know what goes
    17        into our products everywhere in the world.
    18
    19   Q.   But apart from specific ones for a specific country, this
    20        one would be generally applying to all countries?
    21        A.  This would be, yes, that is correct.
    22
    23   Q.   I do not believe that point number 2 has ever appeared on
    24        an addendum before -- what would you say to that -- before
    25        3rd October 1989?
    26        A.  That is your point.
    27
    28   Q.   And it has not been disclosed?
    29        A.  It has not what?
    30
    31   Q.   It has not been disclosed to the court?
    32        A.  As far as I know, this could have happened anywhere
    33        from 1973 on.  If you do not believe it, that is your
    34        choice.  I am well aware that this statement number 2 was
    35        before 1989.  We had it in place.  We had our policy before
    36        we even provide it.
    37
    38   Q.   So you said that you know that you had your policy in place
    39        before it was even published?
    40        A.  That is correct.
    41
    42   Q.   How do you know that?
    43        A.  I had some discussions with some people, including
    44        Mr. Ray Cesca.
    45
    46   Q.   When did he say the policy was brought in and how?
    47        A.  I do not remember.  Mr. Ray Cesca can give you a more
    48        accurate idea.  But I know it was well before, several
    49        years before we even put it into a written policy that it
    50        was in place. 
    51 
    52   MS. STEEL:   Are cattle ----- 
    53        A.  Are we done with this?
    54
    55   Q.   Yes.  Are cattle that are fed or reared on grass leaner
    56        than grain-fed cattle?
    57        A.  It could be; it could be not.  You have to understand
    58        that in the industry there are good pastures, there are bad
    59        pastures.
    60

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