Day 067 - 15 Dec 94 - Page 64
1 question again, I suggest you put it in some more specific
2 way to test it like that.
3
4 MR. MORRIS: OK.
5
6 MR. JUSTICE BELL: You might ask, for instance, whether the
7 letter, the one which he said it was the latest one,
8 I think by that Dr. Gomez Gonzalez meant the one going
9 furthest back, because clearly the one 10 years ago could
10 not have been the latest in time. If you like, ask him
11 whether that was just referring to the state of affairs as
12 it then was, or purported to refer further back, do you see
13 what I mean, about what had happened in the past, or
14 whether he can really remember what the contents of the
15 letter were without actually having it in front of him.
16
17 MR. MORRIS: Let me, first of all, I am not trying to intimidate
18 the witness.
19
20 MR. JUSTICE BELL: Start again then.
21
22 MR. MORRIS: I am trying to identify what I am trying to find
23 out, because it is up to me what questions I ask. I am not
24 saying that he is deliberately avoiding answer the
25 question. I am just trying to clarify what I am trying to
26 ask you. (To the witness): I am trying to clarify, have
27 you seen any documentary evidence before, say, the letter
28 of 1983 or 1984, can you recall seeing any documentary
29 evidence, either in Coope Montecillos' records or in the
30 McDonald's Costa Rica records, which convinced you before
31 that oldest letter that you have seen that they were not
32 exporting to any other McDonald's in the rest of the world?
33 A. Before that time I have not seen any written evidence
34 but, like I said before, I have communicated, talked,
35 discussed and explored that possibility through other
36 means, through our people and our suppliers in the United
37 States as well as our restaurants operations. So, I have
38 not seen any written confirmation or verification prior to
39 that time, but I have talked to numerous people which will
40 give me enough confidence to say -----
41
42 MR. JUSTICE BELL: You have said that before. The question was
43 just about whether you had seen written -----
44 A. No, I have not.
45
46 MR. MORRIS: Coope Montecillos who you work closely with over
47 the last year, yes? You have been in Costa Rica for a long
48 time?
49 A. I have been in Costa Rica for the last three and a half
50 years. On numerous occasions I have worked with Coope
51 Montecillos as well we are currently developing a new
52 supplier called Procarne.
53
54 Q. Just to go from after 1983, you say you have seen something
55 like 20 or 30 documents about this issue of not exporting
56 to any other McDonald's; is that correct?
57 A. You said in 1993?
58
59 Q. No, sorry, documents that date from 1983/4 up to now, you
60 have seen twenty or 30, you said, something like that, more
