Day 098 - 07 Mar 95 - Page 67
1 them into McDonald's beef.
2
3 MR. MORRIS: Yes. Then on two pages further on, the end of the
4 main paragraph in the middle: "The share of the soyabean
5 meal in the total ration for cows" it is the last sentence
6 which is German cows "was estimated at only 1.8 per cent of
7 the total ration in 1984" which is 1.8 per cent of the
8 feed.
9
10 Then if we go to point 6: "Since the already restricted
11 imports of soyabean and soyabean meal from Brazil only"
12 that is his word "amounts to 996,000 tonnes and thus only
13 represents a 21 per cent share of the total imports", by
14 his calculations no more than 8 kilogrammes of soyabean
15 meal of Brazilian origin is used per dairy cow and heifer
16 annually." So he is calculating the average 8 kilogrammes
17 per cow of soyabean meal of Brazilian origin in Germany.
18 Then he talks two pages following on from that at the top
19 of the page: "Because of the natural conditions," etc., he
20 says the use of soyabean meal in Bavaria". Now Bavaria is
21 the hinterland from which ----
22
23 MR. JUSTICE BELL: Can you not give me the page numbers?
24
25 MR. MORRIS: They have not got page numbers.
26
27 MR. RAMPTON: They do. Ten at the bottom, my Lord.
28
29 MR. MORRIS: I am sorry I cannot read them at all. It is
30 paragraph 7.
31
32 MR. JUSTICE BELL: Yes, I have that.
33
34 MR. MORRIS: He says that the Bavarian average is lower,
35 averaging between 5 and 6 kilogrammes per animal annually.
36 Nevertheless, it is this particular region, 80 per cent of
37 the primary animals for the raw product for hamburgers
38 comes from Bavaria." It is our case that McDonald's where
39 their suppliers are based take their cattle primarily from
40 Bavaria which is 80 per cent of the production of raw
41 product for hamburgers in Germany come from Bavaria. As
42 far as we are concerned that admits that for every cow or
43 cattle slaughtered in Germany for hamburgers for
44 McDonald's, or certainly 80 per cent of them, emanate from
45 Bavaria where 5 or 6 kilogrammes -----
46
47 MR. JUSTICE BELL: But between 5 and 6 kilogrammes does not mean
48 if you take every cow in Bavaria it is eating between 5 and
49 6 kilogrammes a year; it means the average for all the
50 cattle. You have read what I have said in my Ruling.
51
52 MR. RAMPTON: My Lord, can I help?
53
54 MR. MORRIS: No, I have not finished.
55
56 MR. JUSTICE BELL: Leave it there for a moment because there is
57 a specific reference.
58
59 MR. RAMPTON: My Lord, it is in the second statement which
60 Mr. Morris resolutely ignores.
