Day 069 - 19 Dec 94 - Page 49
1 make addendums to our specifications, to our products.
2 There are a lot of addendums that have been produced during
3 this time.
4
5 Q. But this particular one is an international addendum,
6 applying to all countries; yes?
7 A. No. It is an international addendum that applies to
8 international countries. There could be another addendum,
9 because there are countries that cannot, for whatever
10 reason -- could be for regulations, because of
11 availability, for whatever reason it might be, for economic
12 reasons -- they could not follow our specification. So, in
13 that case, they have to make an addendum so we know we can
14 record some of the changes, so we do not terminate a
15 supplier because it do something slightly different, and so
16 we have control over what products and we know what goes
17 into our products everywhere in the world.
18
19 Q. But apart from specific ones for a specific country, this
20 one would be generally applying to all countries?
21 A. This would be, yes, that is correct.
22
23 Q. I do not believe that point number 2 has ever appeared on
24 an addendum before -- what would you say to that -- before
25 3rd October 1989?
26 A. That is your point.
27
28 Q. And it has not been disclosed?
29 A. It has not what?
30
31 Q. It has not been disclosed to the court?
32 A. As far as I know, this could have happened anywhere
33 from 1973 on. If you do not believe it, that is your
34 choice. I am well aware that this statement number 2 was
35 before 1989. We had it in place. We had our policy before
36 we even provide it.
37
38 Q. So you said that you know that you had your policy in place
39 before it was even published?
40 A. That is correct.
41
42 Q. How do you know that?
43 A. I had some discussions with some people, including
44 Mr. Ray Cesca.
45
46 Q. When did he say the policy was brought in and how?
47 A. I do not remember. Mr. Ray Cesca can give you a more
48 accurate idea. But I know it was well before, several
49 years before we even put it into a written policy that it
50 was in place.
51
52 MS. STEEL: Are cattle -----
53 A. Are we done with this?
54
55 Q. Yes. Are cattle that are fed or reared on grass leaner
56 than grain-fed cattle?
57 A. It could be; it could be not. You have to understand
58 that in the industry there are good pastures, there are bad
59 pastures.
60
