Day 093 - 28 Feb 95 - Page 45


     
     1        would Tysons do about that?
     2        A.  I do not want to speculate on things that I have not
     3        seen.
     4
     5   Q.   So you do not know what their procedure would be?
     6        A.  I know what their procedure is to prevent it.  I have
     7        not seen -- I have never been in a broiler house where the
     8        ammonia level has been high.
     9
    10   Q.   I do not know where they are, but there were some Tysons
    11        broiler supervisors' reports that were disclosed ------
    12
    13   MR. RAMPTON:  They are in volume -- curiously enough, I was
    14        ahead of Ms. Steel -- IX, yellow IX, tab 2, behind
    15        Dr. Gomez Gonzalez' first statement, together with a number
    16        of others.
    17
    18   MR. JUSTICE BELL:  Look at tab 2, please, Dr. Gomez.
    19
    20   MR. RAMPTON:  The document to which Ms. Steel refers is at the
    21        back, the last document in that collection.
    22
    23   MR. JUSTICE BELL:  I have mine as behind the very first one, I
    24        think.
    25
    26   MR. RAMPTON:  My Lord, I have done it so that the Tyson broiler
    27        supervisors' report is the first document in that slot.  If
    28        the witness would not mind putting them into the file?
    29
    30   MR. JUSTICE BELL:  The only document I have ahead of it is the
    31        HACCP verification.
    32
    33   MR. RAMPTON:  Has your Lordship no other ones?
    34
    35   MR. JUSTICE BELL:  That is the first sheet.  The second sheet is
    36        the broiler supervisors' report.  There is a clip of about
    37        five sheets there, then we go on to correspondence and
    38        other documentation.
    39
    40   MR. RAMPTON:  Yes.
    41
    42   MS. STEEL:  These documents, these Tysons documents, does
    43        McDonald's actually ask to see these?
    44        A.  If we need the need, yes.
    45
    46   Q.   So sometimes you would get copies of this?
    47        A.  If I asked for them, yes.
    48
    49   Q.   Do you ever ask for them?
    50        A.  Excuse me? 
    51 
    52   Q.   Do you ever ask for them? 
    53        A.  You have a copy of them.
    54
    55   Q.   Yes, but do you ever ask for them other than for the
    56        purposes of this case?
    57        A.  No, I have not.
    58
    59   Q.   You have not?
    60        A.  No.  I have discussed with them but I have not asked

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