Day 067 - 15 Dec 94 - Page 61


     
     1        just see something ---
     2        A.  I am glad you clarified that question.
     3
     4   Q.   -- substantial, something you believed because it was
     5        substantial?
     6        A.  I am glad you clarified that question because, no, it
     7        is more than just one letter.  I have seen different
     8        letters as recent as this year.
     9
    10   Q.   Yes, but I am talking about -- as you know, on this subject
    11        the dispute is about what happened in the 1980s, throughout
    12        the 1980s.  How can you say with confidence because you
    13        have seen a letter just last year or the year before --
    14        what I am saying is, did you see any substantial evidence,
    15        going back to the early 1980s, to make you feel you can say
    16        in court that you know they did not export?
    17        A.  A very good question.  Yes, I have seen substantial
    18        evidence from written evidence.  I have had extensive
    19        discussions with Mr. Paul Simmonds regarding this
    20        particular issue.  I have worked with Mr. Simmonds for
    21        three and a half years.  I have developed a very high level
    22        of trust with him.  We have an excellent relationship with
    23        him.
    24
    25        I have worked probably from the countries in which I work,
    26        I have developed the best relationship with Costa Rica,
    27        with Mr. Rodolfo Madrigal.  All of the evidence, when you
    28        put it together, gives me a high level of confidence, a
    29        very high level of confidence, to believe that what I have
    30        seen, what I have heard, what I have discussed, leads me to
    31        believe without any doubt that we have not exported -- our
    32        suppliers in Costa Rica have not exported any McDonald's
    33        products to our suppliers in any part of the world.
    34
    35   Q.   You are aware of this as an important issue, yes, about ---
    36        A.  Absolutely.
    37
    38   Q.   -- Costa Rica?
    39        A.  I am well aware because anything that could potentially
    40        damage our image, anything that could be wrong in either
    41        way, if that has been the case, I would certainly take
    42        action.  If that is the case, I would not accept that
    43        anybody will accuse myself, McDonald's Corporation, without
    44        having any facts to support those accusations.
    45
    46   Q.   Right.  So, all I am saying is you are aware that we have
    47        quoted the Marketing Director of Coope Montecillos on
    48        camera, it is stated on camera that they exported to
    49        McDonald's in the USA.  Are you aware that is what we have
    50        alleged? 
    51 
    52   MR. RAMPTON:  I am making a formal objection. 
    53
    54   MR. JUSTICE BELL:  You do not put that anyway.  All you need to
    55        put, which I think, in fact, Dr. Gomez Gonzalez has already
    56        accepted, that he realises this is an important issue in
    57        the case.
    58
    59   MR. MORRIS:  If, in fact, he did say that which is a matter for
    60        the court -----

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