Day 067 - 15 Dec 94 - Page 61
1 just see something ---
2 A. I am glad you clarified that question.
3
4 Q. -- substantial, something you believed because it was
5 substantial?
6 A. I am glad you clarified that question because, no, it
7 is more than just one letter. I have seen different
8 letters as recent as this year.
9
10 Q. Yes, but I am talking about -- as you know, on this subject
11 the dispute is about what happened in the 1980s, throughout
12 the 1980s. How can you say with confidence because you
13 have seen a letter just last year or the year before --
14 what I am saying is, did you see any substantial evidence,
15 going back to the early 1980s, to make you feel you can say
16 in court that you know they did not export?
17 A. A very good question. Yes, I have seen substantial
18 evidence from written evidence. I have had extensive
19 discussions with Mr. Paul Simmonds regarding this
20 particular issue. I have worked with Mr. Simmonds for
21 three and a half years. I have developed a very high level
22 of trust with him. We have an excellent relationship with
23 him.
24
25 I have worked probably from the countries in which I work,
26 I have developed the best relationship with Costa Rica,
27 with Mr. Rodolfo Madrigal. All of the evidence, when you
28 put it together, gives me a high level of confidence, a
29 very high level of confidence, to believe that what I have
30 seen, what I have heard, what I have discussed, leads me to
31 believe without any doubt that we have not exported -- our
32 suppliers in Costa Rica have not exported any McDonald's
33 products to our suppliers in any part of the world.
34
35 Q. You are aware of this as an important issue, yes, about ---
36 A. Absolutely.
37
38 Q. -- Costa Rica?
39 A. I am well aware because anything that could potentially
40 damage our image, anything that could be wrong in either
41 way, if that has been the case, I would certainly take
42 action. If that is the case, I would not accept that
43 anybody will accuse myself, McDonald's Corporation, without
44 having any facts to support those accusations.
45
46 Q. Right. So, all I am saying is you are aware that we have
47 quoted the Marketing Director of Coope Montecillos on
48 camera, it is stated on camera that they exported to
49 McDonald's in the USA. Are you aware that is what we have
50 alleged?
51
52 MR. RAMPTON: I am making a formal objection.
53
54 MR. JUSTICE BELL: You do not put that anyway. All you need to
55 put, which I think, in fact, Dr. Gomez Gonzalez has already
56 accepted, that he realises this is an important issue in
57 the case.
58
59 MR. MORRIS: If, in fact, he did say that which is a matter for
60 the court -----
