Day 068 - 16 Dec 94 - Page 39
1 evidence is, whatever the position may be, they do not use
2 frozen beef in the US, for the practical reasons which he
3 has given.
4
5 MR. MORRIS: Is that your evidence?
6 A. That is correct. An economic -- well, you have
7 mentioned.
8
9 Q. Can you explain the difference between lean, boneless
10 beef -- sorry, 75 to 90 and 50 per cent; are they mixed up
11 when you make the patty?
12 A. No. That is a description by which the meat is sold.
13 The meat is sold on the value of the lean portion. So when
14 it says 75 to 95 per cent, it could contain a variation.
15 When you buy it, it is classified in that range.
16
17 Q. Is that the better quality, the one with 75 to 95 per cent?
18 A. Not necessarily. It is just the type of cut that we
19 use, a type of meat that we use for our purposes.
20
21 Q. Do you know what percentage of 75 to 95 per cent is bought,
22 as opposed to 50 per cent, roughly; is the majority that
23 you buy, or that your suppliers buy, 50 per cent, or is it
24 75 to 95 per cent?
25 A. If I have understood your question correctly, are you
26 asking me what is the proportion of those?
27
28 Q. Yes -- those different types of beef sources.
29 A. If I give you that, if I have to give you that
30 information, you will have our confidential information
31 which will become public to the public, and which you will
32 have a recipe, basically, to make our patties.
33
34 MR. MORRIS: I do not want to know what you mix in with which
35 patties. I am saying that when you buy your
36 50 million -----
37
38 MR. RAMPTON: My Lord, I am sorry. If the figures are given for
39 purchase, naturally, they might be expected to reflect it
40 in the composition of the patty. Unless Mr. Morris can
41 demonstrate some reason why Mr. Gomez Gonzalez should give
42 the proportions, then I would register an objection to his
43 answering this question for the reason that he has given.
44
45 MR. JUSTICE BELL: I think you can probably approach it another
46 way, without him having to give the confidential figures.
47
48 MR. MORRIS: I do not think it can be more confidential than the
49 specification which we have in front of us.
50
51 MR. RAMPTON: No, my Lord. Mr. Morris does not understand. We
52 necessarily disclose, because English law compels it, even
53 confidential information if it is relevant. If it is not
54 relevant, then we do not.
55
56 MR. JUSTICE BELL: I think you can get what you want
57 without -----
58
59 MR. MORRIS: I just think that is a bogus challenge. But in any
60 case, Mr. Cesca says in his statement -- if I can read it
