Day 068 - 16 Dec 94 - Page 29


     
     1   Q.   Will they be samples of the forms or will they be
     2        summaries, or what will they be?
     3        A.  They will be both.  It is up to them to make summaries.
     4
     5   Q.   How long do they go back till?
     6        A.  I have no idea.  I do not know.
     7
     8   Q.   You saw them?
     9        A.  The ones that I saw, I said they go back, when I asked
    10        for them, a few months.
    11
    12   Q.   So how do you know what is happening, for example, in the
    13        1980s; or do you know what was happening in the 1980s?
    14        A.  I do not know.  I have not seen records from 1980 prior
    15        to my arrival.
    16
    17   Q.   So did, in fact, McDonald's know, prior to your arrival,
    18        what the sources of their beef were?
    19        A.  Did they know?
    20
    21   Q.   Yes -- in Costa Rica?
    22        A.  From my discussions that I have had, yes.
    23
    24   Q.   How did they know that, then?
    25        A.  That they had visited the plant.  We developed the
    26        plant, the process; and, again, Mr. Ray Cesca, who has been
    27        more involved in the rainforest, can provide you with more
    28        information, more detailed information.
    29
    30   MR. MORRIS:   Right.  But you do not know then that -- what do
    31        you know about -----
    32
    33   MR. JUSTICE BELL:  If I might suggest, all you do is keep
    34        provoking him into giving hearsay evidence.
    35
    36   MR. MORRIS:  I understand that.  I am trying to see what he
    37        knows.
    38
    39   MR. JUSTICE BELL:  It is quite clear that Dr. Gomez Gonzales
    40        does not, of his own direct knowledge, about the 1980s.
    41        Why push him into saying that someone else has told him
    42        something about that, which may very well, in so far as it
    43        is evidence at all, be adverse to your case?
    44
    45   MR. MORRIS:  I do not mind if something is adverse to my case if
    46        it is the truth.  The point is, I am trying to
    47        establish  -----
    48
    49   MR. JUSTICE BELL:  The whole point is, we do not know whether it
    50        is the truth, if it is just what someone else has told him. 
    51 
    52   MR. RAMPTON:  My Lord, Mr. Morris does have a problem.  He may 
    53        not think that he does.  He has two problems:  the first is
    54        that hearsay evidence of what a person who is abroad has
    55        told somebody is admissible in certain circumstances.
    56
    57        The other, and more important, point is this:  Mr. Morris
    58        seems to think this is some kind of public inquiry and that
    59        he, in some sense, is counsel to the tribunal.  I have sat
    60        here very patiently for the whole of this morning.  I do

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