Day 287 - 25 Oct 96 - Page 14


     
     1        suppliers in this country of hamburgers, said, that they
     2        get German supplies in this country.  This was at the
     3        bottom of page 42 and top of page 43.
     4
     5   MR JUSTICE BELL:  Which day do you have that?
     6
     7   MR. MORRIS:   Sorry, that is day 78.  But I am not sure of the
     8        exact percentages.  We did have a chart somewhere with
     9        percentages on.  I could not find it.  (Pause).
    10
    11   MR JUSTICE BELL:  Do not slow things up now, because you can
    12        always come back to it and give me the reference later,
    13        Mr. Morris.
    14
    15   MR. MORRIS:   Yes, but if I do not find it now I will probably
    16        never find it.
    17
    18   MR JUSTICE BELL:  Yes, I know.  You quite frankly cannot afford
    19        the time to pause in your submissions until something is
    20        found.
    21
    22   MR. MORRIS:   No.  I am not going to go into the detail of
    23        Schumm's statement, because I am not going to argue that he
    24        does the whole job for us.  So then he says on page 44 of
    25        day 78, "What kind of cow meat would you get from France?"
    26         -- that is line 52 -- "Would you get cows, would you get
    27        steers?"  Answer, "You would get a mixture of both.  I
    28        mean, we buy steer beef from France", and et cetera, et
    29        cetera, et cetera.  Question, "Would that apply to Germany,
    30        as well?"  Answer, "Yes."  So they get both cows and steers
    31        from Germany -- well, cow beef and steer beef from Germany
    32        -- for UK use, for UK customers.
    33
    34        And, as I am going to show -- well, I will not show, but it
    35        is demonstrated by Schumm and other sources -- that we know
    36        that the steer beef uses a greatly magnified amount of feed
    37        from the cow beef, which is all that Schumm concentrated on
    38        in order to, of course, reduce the damage that the issue
    39        was causing in Germany.  There was public criticism.
    40        (Pause) In fact, I think I made the argument which was not
    41        persuasive of you at the time, on day 98, page 66, and so
    42        on.  But I am not hundred percent sure on that.  So that
    43        will save me repeating the whole argument.
    44
    45        I did also put to Mr. Cesca, which I will just flag up a
    46        little bit.
    47
    48   MR JUSTICE BELL:  Yes, I remember that.
    49
    50   MR. MORRIS:   To save you having to go to Schumm's actual 
    51        statement.  I think one of the reasons it was not 
    52        persuasive is, first of all, that there was not in Schumm's 
    53        statement direct relevance to which areas McDonald's cattle
    54        -- well, what McDonald's cattle themselves would be
    55        consuming.  Well, we had a dispute about that.  I felt it
    56        was quite clear, but it was not as clear as may be enough.
    57        But, obviously, Mr. Cesca -- I will go to what Mr. Cesca
    58        said on that subject.  So, that is what I will do now.
    59
    60   MR JUSTICE BELL:  Well, he said, in answer to a question from

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