Day 287 - 25 Oct 96 - Page 08
1 definitions of his shading.
2
3 MR. JUSTICE BELL: Yes, I understand that.
4
5 MR. MORRIS: If you remember, we got a better version of the
6 Cotter map and the shading, the two shading types, sent to
7 us by Dr. Cotter.
8
9 MR. JUSTICE BELL: Do not worry about that.
10
11 MR. MORRIS: Right. It will be our opinion, and the opinion of
12 our experts, that the Cotter map was the minimum defined
13 areas, and our witnesses all said that if anything it was
14 too limited in its area of definition.
15
16 MR. JUSTICE BELL: Just pause there. (Pause). Yes.
17
18 MR. MORRIS: We would say all this is not surprising anyway,
19 because through McDonald's own admission, through the
20 general manager of Procasa supplier, the statement from
21 him, Rolando Roblez -- I am sorry, I do not have the
22 reference, it is McDonald's witness Civil Evidence Act
23 notice statement, when he says how the cattle slaughtered
24 to supply McDonald's in Guatemala come from ranches in
25 regions in Southern Guatemala. This has been the case
26 since Procasa started operations. These regions would be
27 forested in the '40s and early '50s. And that is
28 immediately following a sentence about the rainforest, and
29 that is in paragraph 3 of his statement, and he can only be
30 talking about rainforest.
31
32 And it is further backed up in a letter of Alvaro Cofino,
33 this is Mr. Cesca, in that series of letters from Costa
34 Rica and Guatemala. Mr. Cesca dealt with it in his
35 evidence, where he says -- the last paragraph on page 1 of
36 that letter, and I will probably got the reference in the
37 Cesca transcripts in a minute: "From where the meat plant
38 buy their cattle used to be rainforest but was destroyed at
39 the end of the last century", he says. The point being
40 that that is what he says the government advised him.
41
42 I think the important point about that hearsay opinion is
43 that it is an admission that the area we are talking about
44 is rainforest, the area where they get their cattle used to
45 be rainforest. And the only question is, when was it
46 deforested. He provides a map identifying various areas
47 upon which Mr. Cesca based his McDonald's map, which he has
48 used in this case.
49
50 So the only expert opinion we have heard about the area of
51 deforestation and the type of deforestation is from the
52 work of Cotter and Nations, and the admissions by
53 McDonald's witnesses on that subject.
54
55 Mr. Cesca was asked on day 222, page 35 about IGG, at the
56 bottom of the page, he was asked about the suppliers who we
57 had originally pleaded on Guatemala, in the late '70s, mid
58 '70s, he presumed the beef that supplied them came from
59 the same areas as the ones we are talking about here. That
60 is what he says on the top of page 36. And he presumed
