Day 068 - 16 Dec 94 - Page 49


     
     1
     2   MR. MORRIS:  Before, and specifically within Costa Rica, have
     3        you seen a document which pre-dated, say, 1985, which
     4        specified that Coope Montecillos should not use beef from
     5        certain areas of Costa Rica, certain ranches?
     6
     7   MR. JUSTICE BELL:  Just answer that "yes" or "no"?
     8        A.  Yes.  I am not sure I understood the question.
     9
    10   Q.   Have you ever seen any document in Costa Rica which
    11        indicated that there was any kind of specification,
    12        instruction or policy that Coope Montecillos should not use
    13        rainforest beef?
    14
    15   MR. MORRIS:  Or ex-rainforest, recently deforested?
    16        A.  Yes, I have.
    17
    18   Q.   Can you name that document?
    19        A.  Yes.  I have seen written letters, documented letters,
    20        that were signed by Coope Montecillos, addressed to people
    21        in Costa Rica, addressed to Mr. Ray Cesca, addressed to
    22        Gerry Ford, addressed to another person before, that was
    23        prior to Gerry Ford.  I know it goes back several years.
    24        I am not sure they go back to prior to 1985.
    25
    26   Q.   Just to summarise on this issue -- I think we can move on
    27        after this -- are you saying that McDonald's in Costa Rica
    28        has always had that policy?
    29        A.  What was?
    30
    31   Q.   Have McDonald's, Costa Rica, in your evidence that you have
    32        given, had a policy, always had a policy, that it did not
    33        use any beef reared on recently cleared ex-rainforest?  Was
    34        that always the policy, as you understand it?
    35        A.  That is correct.
    36
    37   Q.   Right.  You have never seen any documentary evidence to
    38        back up your opinion?
    39        A.  I have just stated that I have seen signed letters
    40        where it is described and addressed to the people I have
    41        mentioned before, that the supplier has not used beef from
    42        areas that come from the rainforest, and I have
    43        also -- yes.
    44
    45   MR. MORRIS:   When you were doing your search to back these up,
    46        to try to back up that opinion of those people writing
    47        letters to the company, you did not find a single document
    48        pre-dating 1985 where that was a specification?
    49
    50   MR. JUSTICE BELL:  What are you getting at now? 
    51 
    52   MR. MORRIS:  I am just trying clarify that that is your 
    53        position.
    54
    55   MR. JUSTICE BELL:  Well, it is not, because he said he found
    56        documents at Coope Montecillos, and he cannot say how far
    57        back they went.
    58
    59   MR. MORRIS (To the witness):  You said you found documents,
    60        then, but they were letters?

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