Day 068 - 16 Dec 94 - Page 35


     
     1        A.  The supplier is called Braslo.
     2
     3   Q.   Where in Brazil are they?
     4        A.  They are located close to Sao Paulo.
     5
     6   Q.   Whatever Mr. Cesca may say, or anyone else may say, you
     7        yourself have not seen a similar map of Costa Rica or of
     8        Guatemala?
     9        A.  That is correct.
    10
    11   MR. JUSTICE BELL:  We will come back at two o'clock.
    12
    13                       (Luncheon Adjournment)
    14
    15                                                2.00 p.m.
    16
    17   MR. MORRIS:  Just one thing we touched on this morning:  you
    18        said that you do not use frozen beef products in the
    19        manufacture of patties in the United States; is that
    20        correct?
    21        A.  What I said is that I have not seen any process in
    22        which we have used frozen meat.  I have not seen equipment
    23        required to process frozen meat since I have been with the
    24        company.
    25
    26   Q.   So how many plants do use frozen meat?
    27        A.  Excuse me?  What is your question?
    28
    29   Q.   How many of the plants that you have not seen or what
    30        percentage of the plants that you have not seen use frozen
    31        beef?
    32        A.  About 80 per cent.
    33
    34   Q.   80 per cent ---
    35        A.  80.
    36
    37   Q.   -- do use?
    38        A.  No, no -- that I have seen.
    39
    40   Q.   You have seen 80 per cent of plants?
    41        A.  Yes.
    42
    43   Q.   So of the 20 per cent that you have not seen of the
    44        processed plants, how many of those do use frozen beef?
    45        A.  I do not know.  I cannot tell you.
    46
    47   Q.   So there is no policy against the use of frozen beef?
    48        A.  Absolutely not, no.
    49
    50   Q.   Do you know what percentage of frozen beef you do use in 
    51        the United States? 
    52        A.  No, I do not know. 
    53
    54   MR. JUSTICE BELL:  When the patties have been processed, are
    55        they frozen?
    56        A.  Yes, they are.
    57
    58   Q.   If you got frozen deboned meat to turn into patties, if you
    59        did get it, you could let it thaw and then process it into
    60        patties, you could physically do this, and then freeze it

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