Day 095 - 02 Mar 95 - Page 50
1 A. I cannot speculate on what was Paul's thoughts and
2 ideas at that time. Since just the time that he sent me
3 this information he has sent me thousands of papers that we
4 look at each other so we are aware of operations
5 worldwide. We know that we do not do the same things
6 because we go to different countries, so we have to share
7 that information, we have a better global perspective of
8 our operations.
9
10 Q. OK. He said that these were good terms and definitions
11 and -- what was the purpose? You have discussed this with
12 him. What was the purpose of him saying that? Was it
13 because you were trying to draw up some terms and
14 definitions for a policy on welfare of animals?
15
16 MR. JUSTICE BELL: You accept, do you, that that note reflects
17 Paul Simmons' view?
18 A. Yes.
19
20 Q. Accurately?
21 A. At the time he sent it, yes. After we discussed it
22 about the terminology from freedom from everything, he
23 changed his mind and said "I agree with you", so at the
24 time he was not only looking at this; he was looking at the
25 entire paper. He thought it was a very well written paper.
26
27 Q. Ms. Steel then was asking you for what purpose? Would he
28 get this information just to keep him in the picture or
29 some other application?
30 A. We have constant communications with our operations.
31 I receive a lot of information from Paul.
32
33 Q. Was it just information or for some specific application?
34 A. It was information he was aware I believe at this time
35 that we were involved in this process. It could have been
36 that because I was involved in the process he sent it to
37 me.
38
39 MS. STEEL: What process?
40 A. Of the trial.
41
42 Q. So he only sent it to you while the trial was already going
43 on?
44 A. I do not know when we started this trial. I have been
45 involved for testifying since last December. It could have
46 been one of the causes, yes.
47
48 Q. So you did not see this in 1993 then?
49 A. The date is 1993.
50
51 Q. Yes. I am asking you whether you saw it in 1993?
52 A. I do not remember when I received this paper.
53 Unfortunately Paul did not date it.
54
55
56 Q. Why should Linda Aenkel want a copy if it was in connection
57 with this case?
58 A. Linda, Paul, myself and Lachell Slangmaker, we all work
59 as what we call a "meat group". We all share our best
60 practices. We all share our communications throughout the
