Day 068 - 16 Dec 94 - Page 46


     
     1        A.  Perhaps if I knew the question, I would respond to it.
     2
     3   MR. MORRIS:   How do you respond to that letter?  It seems to
     4        imply there are other regions being used.
     5
     6   MR. JUSTICE BELL:  Why not just ask him if he is any comment to
     7        make?
     8
     9   MR. MORRIS:  Have you got any comment on that letter?
    10        A.  The comment that I know is, that area is, when you see
    11        it on a map, you see it is in the low area; it is not in
    12        the mountains.  So if you fly over that area, there will be
    13        a clear distinction -- and I have passed through that area,
    14        because I fly very often in Latin America -- you can see
    15        the area that is green, and it is higher; you see the
    16        mountains, that is the rainforest.  You see the other areas
    17        where you look, that kind of greyish white.
    18
    19   MR. JUSTICE BELL:  That may be, but do you have any comment?
    20        You were just given the opportunity to comment on the
    21        contents of the letter.  It says nothing about mountains.
    22        A.  When we say "deforested", that does not mean that it is
    23        rainforest.
    24
    25   Q.   Do you have any comment on ---
    26        A.  No.
    27
    28   Q.   -- what is said in that letter?
    29        A.  OK.  No, I do not.
    30
    31   MR. MORRIS:  Rudolfo Madrigal would know that for a fact; he
    32        would know about the sources, would he, as a fact?
    33        A.  Yes, he would.
    34
    35   Q.   That is his job, is it -- part of his job?
    36        A.  That is correct.  I might add that there is another
    37        person, a QA person, a Quality Assurance person, who would
    38         -- one of the two would know, or both.
    39
    40   Q.   You have talked to people in Costa Rica and in McDonald's
    41        and in Coope Montecillos about the controversy regarding --
    42        have you talked to them about both the allegations about
    43        exports to the US and also the use of ex-rainforest land?
    44        A.  I have talked, I have not talked -- you mean, during
    45        the trial?
    46
    47   Q.   No, I do not mean that.  I mean, you know, whenever?
    48        A.  Oh, yes, I have.
    49
    50   Q.   So are you familiar, are you? 
    51        A.  Yes, I am. 
    52 
    53   Q.   You said that you looked into documents and all that kind
    54        of stuff ---
    55        A.  That is correct.
    56
    57   Q.   -- to satisfy yourself?
    58        A.  Yes, sir.
    59
    60   Q.   How seriously, did you get the impression, did McDonald's

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