Day 095 - 02 Mar 95 - Page 50


     
     1        A.  I cannot speculate on what was Paul's thoughts and
     2        ideas at that time.  Since just the time that he sent me
     3        this information he has sent me thousands of papers that we
     4        look at each other so we are aware of operations
     5        worldwide.  We know that we do not do the same things
     6        because we go to different countries, so we have to share
     7        that information, we have a better global perspective of
     8        our operations.
     9
    10   Q.   OK.  He said that these were good terms and definitions
    11        and -- what was the purpose?  You have discussed this with
    12        him.  What was the purpose of him saying that?  Was it
    13        because you were trying to draw up some terms and
    14        definitions for a policy on welfare of animals?
    15
    16   MR. JUSTICE BELL:  You accept, do you, that that note reflects
    17        Paul Simmons' view?
    18        A.  Yes.
    19
    20   Q.   Accurately?
    21        A.  At the time he sent it, yes.  After we discussed it
    22        about the terminology from freedom from everything, he
    23        changed his mind and said "I agree with you", so at the
    24        time he was not only looking at this; he was looking at the
    25        entire paper.  He thought it was a very well written paper.
    26
    27   Q.   Ms. Steel then was asking you for what purpose?  Would he
    28        get this information just to keep him in the picture or
    29        some other application?
    30        A.  We have constant communications with our operations.
    31        I receive a lot of information from Paul.
    32
    33   Q.   Was it just information or for some specific application?
    34        A.  It was information he was aware I believe at this time
    35        that we were involved in this process.  It could have been
    36        that because I was involved in the process he sent it to
    37        me.
    38
    39   MS. STEEL:   What process?
    40        A.  Of the trial.
    41
    42   Q.   So he only sent it to you while the trial was already going
    43        on?
    44        A.  I do not know when we started this trial.  I have been
    45        involved for testifying since last December.  It could have
    46        been one of the causes, yes.
    47
    48   Q.   So you did not see this in 1993 then?
    49        A.  The date is 1993.
    50 
    51   Q.   Yes.  I am asking you whether you saw it in 1993? 
    52        A.  I do not remember when I received this paper. 
    53        Unfortunately Paul did not date it.
    54
    55
    56   Q.   Why should Linda Aenkel want a copy if it was in connection
    57        with this case?
    58        A.  Linda, Paul, myself and Lachell Slangmaker, we all work
    59        as what we call a "meat group".  We all share our best
    60        practices.  We all share our communications throughout the

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