Day 068 - 16 Dec 94 - Page 34


     
     1        or two questions about where we have got to.  The
     2        rainforest countries you are concerned with in relation to
     3        McDonald's, as I understand it, are Costa Rica, Guatemala
     4        and Brazil; Brazil for a different reason to Costa Rica and
     5        Guatemala, but those are the three.  It sounds as if you
     6        think that in relation to each of those countries there is
     7        a map somewhere which, at some time in the past, has
     8        purported to define what parts of that country were at that
     9        time rainforest or not rainforest; is that what you are
    10        saying?
    11        A.  That is correct.  I have seen the maps in Brazil, and
    12        in Guatemala I have not seen the map, because we source
    13        from a supplier that is not -- we know the supplier.
    14
    15   Q.   All I am asking you about maps is: do you know whether
    16        there is a map in relation to Guatemala?
    17        A.  I have not seen it.  Mr. Ray Cesca can probably give
    18        you a better answer.
    19
    20   Q.   Do you know whether there is a map in relation to
    21        Costa Rica?
    22        A.  I was thinking very heavily into that.  I am not sure.
    23        I seem to recollect that I have seen it, but I am not sure.
    24
    25   Q.   You have seen one in relation to Brazil, have you?
    26        A.  That is correct.
    27
    28   MR. MORRIS:  So the Brazil map, is that something that
    29        McDonald's have a map, they have areas marked out and they
    30        will say:  "Across this line we will not touch"; is that
    31        what the situation is?
    32        A.  Before I answer, I need to explain what it is, describe
    33        to you that map.  It is big map, the size of a wall, a
    34        normal wall in a house.  It shows the areas in different
    35        colours:  the green will show us the rainforest, and a
    36        brown will show us the dry area.  Within those lines, there
    37        is a line that will go around underneath the Amazon area.
    38        Below that line, there are pins that will identify the
    39        areas of the farms from which we buy the cattle.
    40
    41        There are records then of every farm that we buy that will
    42        describe that facility.  We have historical information
    43        from the suppliers.
    44
    45        So, to answer your question, that is what we go by, yes.
    46        We know the suppliers.
    47
    48   Q.   That map is in your offices in Brazil?
    49        A.  It is in our offices, but it was a map designed and
    50        agreed by many people. 
    51 
    52   MR. JUSTICE BELL:  Forget that.  Where is the map; when did you 
    53        last see it?
    54        A.  When I saw it, it is at the supplier's office, at the
    55        meeting room, at the conference room.
    56
    57   Q.   In Brazil?
    58        A.  In Brazil.
    59
    60   Q.   Which is the supplier?

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