Day 287 - 25 Oct 96 - Page 18


     
     1        terms of both soya beans and soya bean meal? "  Answer,
     2        "The numbers for soya bean would more than indicate that,
     3        yes", which, we would say, completely destroys the
     4        plaintiffs' opportunistic line that we do not have to worry
     5        about the soya bean meal because it is only some kind of
     6        by-product and not relevant.  If that is true, why have a
     7        policy on it, you might argue.  He recognised it as a major
     8        contributory factor to the increasing export potential.
     9        Then he says, "We never had a policy on soya beans", and
    10        that is that same page 19, line 38.
    11
    12        Then on page 20, line 20, he was asked about this policy
    13        that he did not know about and he said, "You asked me a
    14        question whether any soya bean is used in the production of
    15        cattle, and of course it is in a very small quantity."  He
    16        goes on, and I think that is a recognition that soya bean
    17        is a standard feed around the world.  I am not saying every
    18        country, but it is widespread, and it is so obvious that he
    19        would not be expected to identify which countries.  I think
    20        that is his evidence.
    21
    22        As far as Schumm is concerned, Schumm, as far as I can make
    23        out, worked for Sudfleisch, McDonald's sole supplier in
    24        Germany.  I don't know if I am wrong about that.  It says,
    25        in his statement, expert opinion, it says something like
    26        Department for Research Development and Consultation and in
    27        brackets, it has 'logos, Sudfleisch, Freischland'.  So I
    28        presume that he works for Sudfleisch, so he worked for
    29        McDonald's supplier, so he is not an independent expert, he
    30        is part of the...  He worked for the...  Not only is he not
    31        independent, but he is part of the chain of causation of
    32        the problem, so it is extremely unlikely in a consultant's,
    33        in a commissioned, report for McDonald's he is going to
    34        make any concessions, except for extremely reluctantly; and
    35        I think, therefore, his conclusions are very poor quality.
    36
    37        But his information we are not challenging, in terms of the
    38        figures he is using.  He clearly understands the statistics
    39        regarding the industry.  But there is no indication,
    40        anyway, of any understanding or expertise of any kind
    41        relating to the effect that the beef industry would be
    42        having in Brazil.  He can only really talk about the soya
    43        usage in Germany.  So, when he concludes that although --
    44        and, do not forget, he concentrates entirely on cows.  For
    45        example, even if only two percent of McDonald's beef
    46        supplies in Germany come from steers or bulls, if each of
    47        those steers or bulls consumes 50 times as much or a
    48        hundred times as much -- we do not know -- as a cow (which
    49        he says it is irrelevant to compare because it is so much
    50        greater for other cattle apart from cows), then one steer 
    51        or one ----- 
    52 
    53   MR. JUSTICE BELL:  I am not going to speculate.
    54
    55   MR. MORRIS:   No.  But it is obvious that it can have a greater
    56        effect.  In fact, it might be, in the end, that ten times
    57        as much soya gets eaten by the two percent of steers or
    58        bulls that are used or that end up there for McDonald's
    59        use; and, certainly, other countries, where they may be
    60        50 percent of the stock used, of the raw material.  We can

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