Day 069 - 19 Dec 94 - Page 48


     
     1        A.  The main purpose of our product specification is
     2        directed specifically at the product, at the process raw
     3        materials, to use, not to use, what the product should look
     4        like and how to make it.  That is what it does.  It can --
     5        as you can see here -- it includes part of our policy.
     6        That does not mean that no other policies are in place or
     7        do not exist or they have not existed.
     8
     9   Q.   So you have seen it on the specifications before 1989; yes?
    10        A.  I am not sure.  I do remember that it has been there.
    11        I know that it was there before 1989, but I think the specs
    12        contain it, yes.
    13
    14   Q.   So you have actually seen it in a document?
    15        A.  Yes, I have seen it in a document, yes; and if I may
    16        add, Mr. Ray Cesca will give you all the details; he is a
    17        better qualified person on the rainforest.
    18
    19   MR. MORRIS:   I think it goes without saying that we will be
    20        formally requesting that tomorrow.
    21
    22   MR. RAMPTON:  Requesting what?
    23
    24   MR. MORRIS:  The back documents from the international product
    25        specifications which Dr. Gomez Gonzalez has seen.
    26
    27   MR. RAMPTON:  My Lord, by all means.  The more documents
    28        McDonald's can find to fuel their case and destroy the
    29        Defendants', the better.  The further back in time we can
    30        go, the better.  If we cannot find anything; we cannot find
    31        anything.
    32
    33   THE WITNESS:   I did say that I am not sure.  I did say I have
    34        seen it in other documents.  I did say this specification
    35        goes back to 1973, which makes a specification where the
    36        rainforest was there.
    37
    38   MR. MORRIS:  It was there in 1973?
    39        A.  I do not know.  But what it says, at this date, this
    40        product specification -----
    41
    42   MR. JUSTICE BELL:  Yes.  You have said that.
    43        A.  He wants to see more specs that might not exist.  When
    44        I answered my question, it implies this specification goes
    45        back to those dates.
    46
    47   MR. MORRIS:  When it says it is an addendum dated November 7th,
    48        1973, does that mean there was an international addendum at
    49        that time?
    50        A.  Yes. 
    51 
    52   Q.   To the ----- 
    53        A.  To the US specification, yes.  So it could have been
    54        that the addendum was the introduction of the rainforest
    55        policy into that issue back in 1973.
    56
    57   Q.   You have these addendums going back to 1973; you have seen
    58        them, have you?
    59        A.  I have seen numerous addendums.  As you would imagine,
    60        there are times and there are countries where we have to

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