Day 102 - 13 Mar 95 - Page 32
1 MR. JUSTICE BELL: Yes, just pause for a moment.
2
3 MR. MORRIS (To the witness): The various departments -- do you
4 have people that work under you looking at the various
5 parts of the procedures at Sun Valley?
6 A. The people that work for me would have -- for example,
7 I have a company veterinary surgeon who is responsible for
8 day-to-day diagnostic work on farms, so I would obviously
9 discuss with him from time to time various procedures.
10
11 Q. What I mean is are there different departments at Sun
12 Valley or different jobs over-looking the whole process?
13 For example, do you have somebody who is responsible for
14 building design?
15 A. Yes.
16
17 Q. And somebody who is responsible for food quality in terms
18 of the final product?
19 A. Yes.
20
21 Q. Do you have someone who is responsible for, you know,
22 nutrition ---
23 A. Yes.
24
25 Q. -- for the birds?
26 A. Well, we do have these various people. Most of them
27 would not report to me directly.
28
29 Q. Could you just say, can you just go through those
30 positions? Is there a specific whose job is nutrition, for
31 example?
32 A. Yes, there is.
33
34 Q. Could you give their job description, their name?
35 A. Well, the nutritionist is responsible for formulating
36 all the rations for the birds.
37
38 Q. There is a specific job, is there, for monitoring the food
39 quality of the animals? I do not mean at the very end of
40 the process; I mean to be concerned about that issue all
41 the way through?
42 A. Well, for the quality control of the actual feed that
43 goes to the animals, that is the nutritionist's
44 responsibility.
45
46 Q. I did not mean that. I mean is there somebody who is
47 responsible for monitoring the quality of the bird's flesh,
48 if you like, at each part or am I -----
49 A. Not one specific person, I think no.
50
51 Q. You have a nutritionist, have you got any other -- I am
52 trying to find out which particular people are responsible.
53
54 MR. JUSTICE BELL: Just give one or two examples. We probably
55 do not need to go through the whole lot for your purposes
56 on this. You want to ask him whether you have an
57 equivalent person with regard to the welfare of the birds
58 on the farms; is that your point?
59
60 MR. MORRIS: Yes. (To the witness): So you have a building
