Day 287 - 25 Oct 96 - Page 07
1 MR. MORRIS: I will accept that, yes.
2
3 MR. JUSTICE BELL: Yes.
4
5 MR. MORRIS: Obviously, I will not repeat the general case for
6 Guatemala, that there would exist for Brazil and Costa Rica
7 and global all the various levels of responsibility of
8 McDonald's for deforestation and that deforestation would
9 be continuing.
10
11 MR. JUSTICE BELL: Yes.
12
13 MR. MORRIS: Progressive deforestation.
14
15 MR. JUSTICE BELL: Yes.
16
17 MR. MORRIS: And obviously the well-appreciated -- well, expert
18 opinion that the forested areas, and we are talking here
19 about tropical rainforest as defined by Dr. Cotter, were
20 outside of those areas. There would obviously be spurs and
21 areas of similar vegetation, but probably not in such a
22 solid substantial block and therefore do not appear on the
23 map.
24
25 MR. JUSTICE BELL: Yes.
26
27 MR. MORRIS: For example, when we look at the Cotter map, as
28 regards Costa Rica, he does not include the areas that are
29 defined as rainforest by Tozey, in the northern and
30 northeastern parts or border of Guanacaste, maybe because
31 the size is too small to notice on his very small scale
32 map. Those areas, yes. Those areas would be accepted by
33 everybody as rainforest under any definition. But he also
34 obviously does not include other tropical forests, because
35 in Costa Rica on that same map he does not note the
36 deforestation that has occurred in Guanacaste or Nicoya,
37 which we have heard evidence about.
38
39 So with all those what we might call drastic limitations
40 that Dr. Cotter set himself based upon his work with Dr.
41 Nations, we can still say that McDonald's in Guatemala is
42 clearly using beef reared on recently deforested
43 ex-rainforest land, recent in terms of since the '40s for
44 certain. And, of course, bearing in mind all the
45 limitations of the Cotter map, we would say that that
46 extensiveness and progressive deforestation is not taken
47 into consideration. The deforestation occurred between
48 1940 and 1982 according to the Cotter map, up to 1982.
49
50 And I am going to say that all this is not surprising,
51 because the statement from Rolando Roblez -----
52
53 MR. JUSTICE BELL: When you said the dotted was surviving
54 rainforest, I thought you said in 1992?
55
56 MR. MORRIS: No.
57
58 MR. JUSTICE BELL: Did you say 1982?
59
60 MR. MORRIS: 1982. I am basing it on the Cotter map and his
