Day 068 - 16 Dec 94 - Page 37


     
     1        use frozen raw material; is that, as you understand it, a
     2        specification?
     3        A.  OK.  Not necessarily.  This specification is also, even
     4        though on the top it says "US frozen meat patty", it
     5        describes the type of patty, that is our name.  It does not
     6        imply that it is only for the US.  We use the specification
     7        globally to assure consistency and to have the same
     8        product.  If we modify that, there are specification
     9        addendums (sic) that I believe are included.
    10
    11   Q.   International?
    12        A.  International.
    13
    14   Q.   Which say that you can use frozen.  I saw that.
    15        A.  It does say in the international specifications that we
    16        can use frozen.
    17
    18   Q.   You can?
    19        A.  Yes, if you look -----
    20
    21   Q.   But in the US itself, is that a specification then that is
    22        compulsory on the suppliers?
    23        A.  It is, if you look specifically, not for all the raw
    24        materials on top; and if I might describe so that you can
    25        have a better idea, it says "minimum 50 per cent lean,
    26        boneless meat".  It is a specific type of meat.  It is,
    27        when we say "fresh only, not frozen" it is directly related
    28        to that specific 50 per cent lean meat, boneless meat.
    29
    30   MR. MORRIS:   Is there other meat that is used?
    31
    32   MR. JUSTICE BELL:  Look at the page before.
    33
    34   MR. MORRIS:  So the meat that is 75 per cent and 95 per cent
    35        lean, boneless beef does not have a specification that it
    36        must be frozen; yes?
    37        A.  I am sorry.  Which one?
    38
    39   MR. JUSTICE BELL:  Page 19.
    40        A.  The 75 to 95 per cent, right?
    41
    42   MR. MORRIS:  Yes.
    43        A.  That is correct.
    44
    45   Q.   So ----
    46        A.  Just to clarify my answer, your question was that the
    47        75 per cent to 95 per cent lean, boneless meat is not to be
    48        used in a frozen stage, right, is that correct?  Is that
    49        what you asked me?
    50 
    51   Q.   It should not be frozen when it arrives.  What I am trying 
    52        to establish -- it is not a trick -- is whether you are 
    53        saying that you have never seen any frozen beef, raw
    54        material, in any of your process plants?
    55        A.  That is correct.
    56
    57   MR. MORRIS:   You do not know what happens in the other
    58        20 per cent?
    59
    60   MR. JUSTICE BELL:  He says he has not seen the other

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