Day 158 - 19 Jul 95 - Page 34


     
     1        if I can hand this up.  (Handed)  Pages 31 to 33.  Shall
     2        I take you to what I think the relevant bits are?
     3
     4   MR. JUSTICE BELL:  Is it just page 32, lines 7 to 16?
     5
     6   MR. MORRIS:  Well, it is page 31, 9 to 16.
     7
     8   MR. JUSTICE BELL:  Yes.
     9
    10   MR. MORRIS:  Then it is page 32, 7 to 20.
    11
    12   MR. JUSTICE BELL:  Yes.
    13
    14   MR. MORRIS:  It is page 32, 38 to 49.  I think that is really
    15        the main -- it is possibly also, if it makes any
    16        difference, page 33, lines 33 to 36.
    17
    18   MR. JUSTICE BELL:  Which page?
    19
    20   MR. MORRIS:  33, lines 33 to 46.
    21
    22   MR. JUSTICE BELL:  Yes.
    23
    24   MR. MORRIS:  The effect of that, in fact, we would argue, is
    25        stronger than what we have written in the amended pleading,
    26        which is that the policy from Mr. Gomez Gonzalez -- who,
    27        I believe, is international marketing director, or meat
    28        purchasing director; I cannot remember exactly -- was that
    29        it was basically fair game to use beef raised on land,
    30        effectively, that had been rain forest up to the minute
    31        that McDonald's opened up in a particular country, and that
    32        any forest destroyed after that, they would put a ring
    33        fence round, which would mean in the Brazilian case that
    34        any land destroyed before 1979 could be quite happily
    35        available to McDonald's from thereonafter; that they would
    36        not reject a consignment from such land.
    37
    38        As we have heard, there was possibly -- I cannot remember
    39        what the exact reference is, but certainly -- well, as we
    40        have said in the pleading, 1966 to 1975 was a substantial
    41        time of both rain forest and tropical forest destruction,
    42        and the responsibility of cattle ranching for it was highly
    43        significant.
    44
    45        Can I just add that the colonisation in that sentence in
    46        our pleading, "a further 30 per cent by way of
    47        colonisation", if we look to the evidence from our witness
    48        Mr. Monbiot, is that the colonisation is a cause of
    49        rain forest -- is caused by, the principal cause of
    50        colonisation into the Amazon is from cattle ranching 
    51        outside the Amazon.  So the colonisation mention is 
    52        something which McDonald's have a responsibility -- have 
    53        aided it, which is why it was specifically mentioned.  We
    54        do not mention the timber industry; it was not relevant to
    55        that pleading.  I think that deals with our entire
    56        submission.
    57
    58   MR. JUSTICE BELL:  Just let us look a moment, because you have
    59        concentrated on paragraph 1, first of all.
    60

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