Day 068 - 16 Dec 94 - Page 58


     
     1        first page -- it is Jill Chang.  She is our McDonald's
     2        country purchasing manager.
     3
     4   Q.   In Taiwan?
     5        A.  In Taiwan.
     6
     7   Q.   So she filled out this form.  I notice that the English, in
     8        general, is very good, is it not?
     9        A.  Yes.
    10
    11   Q.   "Covered yards" and "sprinklers" or "springlers".  Then
    12        under:  "Are animals rested prior to stunning and
    13        slaughtering?"  "Yes, minimum 24 hour".  That seems to be
    14        very colloquial in English.  So, the person doing this
    15        seems not to have a problem with English, do they?
    16        A.  That is incorrect.  I know Jill.  I have talked to her
    17        and, if you look at this form, it is not, it is not easy to
    18        say, write -- "Yes, min. 24 hours", it does not take a lot
    19        of English to write that.  It does take a considerable
    20        mental effort for a person who speaks, I think it is,
    21        Mandarin language.
    22
    23   MR. JUSTICE BELL:  What are you suggesting, Mr. Morris?
    24
    25   MR. MORRIS:  I am suggesting that when they say "Product
    26        exported to (country), Japan, USA, Taiwan", yes, that is
    27        what they are exporting to McDonald's in those countries,
    28        for McDonald's use, that is.
    29
    30   MR. JUSTICE BELL:  What do you say about that?
    31        A.  That is thoroughly incorrect.
    32
    33   MR. MORRIS:  How do you know?
    34        A.  Because I know.  I have been in all zones.  I have been
    35        in those areas -- I know.  That is not, it does not make
    36        any sense, even economically, to do that, to move product
    37        from Australia to Taiwan to the United States when it is
    38        cheaper to have it in the USA in the first place.
    39
    40   Q.   It does not say, does it, "through Taiwan"?  It says that
    41        is where this plant is exporting to, Latchley Meats,
    42        Australia  ---
    43        A.  OK.
    44
    45   Q.   -- is exporting to Japan.
    46        A.  OK.  They made a mistake.  They do not export to
    47        Australia.  They import raw materials from Australia.
    48
    49   MR. JUSTICE BELL:  No.  What Mr. Morris is suggesting is that,
    50        on the face of it, the information which has been put on 
    51        your questionnaire means that Latchley Meats export beef 
    52        from Australia to Japan, to the USA, and to Taiwan --- 
    53        A.  No.
    54
    55   Q.   -- first of all and, secondly, he suggests that it means
    56        they not only export Australian beef to those countries but
    57        to McDonald's in those countries, that is his suggestion.
    58        A.  OK.  They do export raw materials to Japan, to the US
    59        and Taiwan, that is correct.  They do not export, nor do
    60        they have the capability, to process finished patties so,

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