Day 007 - 06 Jul 94 - Page 37


     
     1
         MR. JUSTICE BELL:   This is a very convenient way of having it
     2        done for one, but so that the defendants hear (in case it
              is not obvious) this witness is doing the arithmetic for
     3        us which we could do ourselves.
 
     4   MR. RAMPTON:  It is only so that we can get it on the
              transcript, and so one can have a very rough figure for
     5        the total square mileage of timberland used by McDonald's
              annually throughout the world.  If it is 9.4 in the United
     6        States, and 1.3 in Europe and 2.9 in the rest of the
              world, we get a total of 13.6 square miles per annum?
     7        A.  That would follow, yes.
 
     8   Q.   Having, as it were, looked at or verified that last
              exercise we have just done, Mr. Kouchoukos, does it seem
     9        to you that what we have come up with is a fair figure?
              An exagerration?  Or a gross under estimate?
    10        A.  I think it is very fair figure, probably on the high
              side.
    11
         Q.   Why do you think it might be on the high side?
    12        A.  Because in the numbers that I calculated I used all
              trees, all types, all types of pulping processes, and in
    13        fact the pulping processes that are dominant in the
              packaging industry are more efficient than what is stated
    14        as the overall average.  So, it is a conservative
              estimate.
    15
         Q.   If you use acreage or square mileage you under- estimate
    16         --- You might be under- estimating the density of the
              trees in each square mile?
    17        A.  That is correct, especially in a pine plantation or
              where the trees are closer.
    18
         Q.   Do you distinguish (and this is not really a question for
    19        you) in point of density between a natural forest and one
              which is grown for commercial reasons?
    20        A.  You can distinguish.  I did not distinguish the
              differences in my estimate, no.
    21
         Q.   Would a plantation forest generally, do you know, be
    22        denser than a natural forest?
              A.  I would certainly expect so, yes.
    23
         Q.   There are two more things I would like to ask you about;
    24        The first is, going back now to just the United States,
              where the trees come from which are used for McDonald's
    25        paper ---- Do you still have the yellow file?
              A.  I have. 
    26 
         Q.   Can you go to the back of it which is divider four, and 
    27        your second statement?
              A.  Okay.
    28
         Q.   Is the first document in that ---- Mine has a handwritten
    29        2 on it.  Is it a table of headed 'Perseco/McDonald's
              Supplier Pulp Bleaching Summary'?
    30        A.  That would be 3 pages back, 338.
 

Prev Next Index