Day 102 - 13 Mar 95 - Page 37


     
     1
     2   Q.   Is that something that is done straightaway?
     3        A.  Well, it is done as soon as they are ready to start the
     4        catch, they will do that.
     5
     6   Q.   So they open the doors as soon as they are ready and then
     7        they go in and start moving them?
     8        A.  That is right, and that is after they have obviously
     9        lifted any equipment like feeders or drinkers out of the
    10        way first.
    11
    12   Q.   So before the doors are opened someone will go in there
    13        lifting all the equipment out of the way?
    14        A.  Yes.
    15
    16   Q.   To move the birds out of the way, the catchers would use a
    17        similar method to shown in the film; is that right?
    18        A.  The film showed a practice which is not acceptable,
    19        waving bags, kicking birds -- that is not the way to move
    20        them.
    21
    22   Q.   In what way do you say that catchers at Sun Valley are
    23        instructed to move the chickens out of the way?
    24        A.  They are asked to herd the birds sideways using methods
    25        which are going to give the birds time to move and not to
    26        put them in a panic.
    27
    28   Q.   What methods are they?
    29        A.  Well, just to use common sense, herding the chickens.
    30
    31   Q.   How do you herd a chicken?
    32        A.  Like this.  (Indicating).
    33
    34   Q.   Like that.  That is what they are instructed to do, is it?
    35        A.  Yes.
    36
    37   Q.   Is that what has happened when you have watched?
    38        A.  Yes, it is.
    39
    40   Q.   You have never seen anything different to that?
    41        A.  I have not seen that bag flapping, no.
    42
    43   Q.   How long should they take to herd the chickens out of the
    44        way?
    45        A.  Well, it is done as quickly as possible.  It normally
    46        takes 10 or 15 minutes.
    47
    48   Q.   To create what amount of space are we talking about?
    49        A.  To create enough space for the tractor unit to be able
    50        to deposit modules inside the sheds.  Usually, four or five 
    51        modules are placed in at a time. 
    52 
    53   Q.   On top of each other or side by side or what?
    54        A.  No, they are placed in a sort of herring bone pattern.
    55
    56   Q.   Right.  Would that be for one truck load at a time?
    57        A.  The whole -- the modules from a whole truck load would
    58        not all be put in the house at the same time.
    59
    60   MR. RAMPTON:  My Lord, I wonder -- I am just looking back at the

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