Day 067 - 15 Dec 94 - Page 60


     
     1   MR. JUSTICE BELL:  He said "McDonald's records".
     2
     3   MR. MORRIS:  So is it a fact then that Coope Montecillos keeps
     4        records for much longer than that time?
     5        A.  Our suppliers, yes?
     6
     7   Q.   Yes, in this case Coope Montecillos keeps its records much
     8        longer than -----
     9        A.  We do not tell our suppliers how long or how to manage
    10        their business.  It is entirely up to them.  We have no
    11        control over that.
    12
    13   Q.   In other words, what I am saying is the records that you
    14        have seen do go back before you joined the company.  You
    15        have seen records going back further than that?
    16        A.  Yes, I have seen some of those.
    17
    18   MR. JUSTICE BELL:  Why not just ask how far back they were and
    19        see if he can remember..
    20
    21   MR. MORRIS:  How far back have you seen them to be able to say
    22        with confidence they never exported?
    23        A.  Probably 10 years, and Ray Cesca will bring those
    24        records.  You also have to understand, we do not destroy
    25        all our documents.  We do not purge them.  There are some
    26        critical records that we do keep.  This just happened to be
    27        one somebody else before me decided to keep them.  We will
    28        probably keep -- I have not destroyed and I will not some
    29        of the records that I have circulated that I have in my
    30        possession for more than three years.
    31
    32   MR. JUSTICE BELL:  I am sorry, I may have got a bit confused.
    33        I thought that the records you were talking about seeing
    34        were Coope Montecillos records which you saw in Costa Rica?
    35        A.  That is correct.  That is part of it, yes.
    36
    37   Q.   Your evidence is that you looked at their records and there
    38        were no records of exported beef to McDonald's in the US or
    39        for McDonald's in the US, is that what you are saying or
    40        not?
    41        A.  That is correct, yes.
    42
    43   Q.   What are the McDonald's records you are saying now someone,
    44        in fact, kept beyond the normal three year period which you
    45        have looked, at what kind of records are those?
    46        A.  There was signed letters from our suppliers indicating
    47        that they have not exported products, and they have
    48        specifically mentioned to the US, from their facilities to
    49        any of our suppliers.  That is what they indicated.
    50 
    51   Q.   How far did they go back? 
    52        A.  I do not know how far they go back, but I have seen 
    53        documents that are around 10 years old.
    54
    55   MR. MORRIS:  I mean, was that one letter 10 years ago or was it
    56        a whole file?
    57        A.  No, I said, the question was how far, so I said up to
    58        10 years I have -----
    59
    60   Q.   All I am saying is did you just see one letter or did you

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