Day 067 - 15 Dec 94 - Page 59


     
     1        to Japan and the US.
     2        A.  OK.  You have to keep in mind that it does not mean
     3        McDonald's.  We ask at the top, it is the supplier, it is
     4        not us.  This particular supplier exports or has to export
     5        a product to the US and Japan.  It does not imply, and
     6        I know they do not export McDonald's products to Japan or
     7        the US.
     8
     9   Q.   But you said before that that box No. 3 when we went
    10        through them, meant that it exported to McDonald's.  When
    11        we went through a lot of them you said, yes, you knew they
    12        did X-Y-Z.  Obviously, many places might export to 30 or 40
    13        countries if they are big suppliers.  It is only relevant,
    14        is it not, if it is going to you?
    15        A.  No, it is not relevant.  The question is the product
    16        exported to.  I probably failed to clarify what the product
    17        was, but it comes under the supplier.  They are suppliers
    18        that are approved and they are currently supplying other
    19        countries.  It does not necessarily imply that we have
    20        received or bought or used some of that product that came
    21        from that country.  In this particular case our supplier in
    22        Costa Rica has never ever supplied McDonald's Japan or the
    23        US.
    24
    25   Q.   Since you have heard of anyway?
    26        A.  Since I heard of, since I have communicated with our
    27        people, and I am sure that Ray Cesca will come up with
    28        documents, signed documents from those people and the
    29        records to prove that.  If you have any evidence that they
    30        do I would certainly like to see it.
    31
    32   Q.   So how can you be sure?  Have you seen the records they
    33        have got?
    34        A.  I have seen what they have produced.  I know the
    35        countries in which we operate, in this specific case Japan
    36        in the US.  I have been in Japan and obviously I live in
    37        the US.  I know where they buy the beef.  I know the
    38        process that is in place before we approve any export.  We,
    39        McDonald's, approve the export of any McDonald's product,
    40        the handling of any McDonald's product.  It has to come
    41        through us.  There is no record, there has never been a
    42        record of any Costa Rican supplier who has supplied any
    43        other countries, any other McDonald's restaurants around
    44        the world.
    45
    46   Q.   So when you were in Costa, that is from your own
    47        experience, you have seen the records and you can say that
    48        with confidence?
    49        A.  Yes, I do.
    50 
    51   Q.   Because you have seen the records? 
    52        A.  I have seen records.  I have seen the plants.  I have 
    53        asked them.  I have asked our suppliers.  I have asked our
    54        people that are responsible for the zones.  That gives me
    55        total confidence that it has not happened in the past.
    56
    57   Q.   You said, for example, that records were only kept for
    58        three years as a general rule, so how can you say that?
    59        I mean, what have you seen ----
    60

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