Day 313 - 13 Dec 96 - Page 30
1 language is not admissible itself as evidence, which indeed
2 may be the case, then the Portuguese language map from
3 Brazil is not admissible as evidence. It is only a guide
4 to an expert who interprets it in the witness box, and I
5 would say that we are not stating that documents in another
6 language are admissible as evidence in this case, but we
7 are saying they are capable of being interpreted by experts
8 in the witness box who appreciate what is being said in
9 that document or enable to interpret it to the court. So,
10 in fact, the Portuguese map in itself is probably under the
11 law not admissible as evidence except as a tool for an
12 expert in the witness box.
13
14 Can I just say, in terms of accuracy of figures there is a
15 whole series of figures in the rainforest submissions on
16 pages 25, 27 -- well, 34 and 35, and in fact table 1
17 and... Yes, table 1, and all the figures regarding
18 McDonald's, which relate to McDonald's responsibility, have
19 to be multiplied by ten in terms of head of cattle, which
20 is something that has come up a number of times in the
21 case, so when, for example on page 25, McDonald's say that
22 their annual consumption of cattle in Brazil was 40,000
23 head, the actual number of cattle that would have been
24 needed for McDonald's use would have been 400,000, of which
25 they would have taken ten per cent. So when they say their
26 total was 0.22 per cent of the annual national total it is
27 in fact that 2.2 per cent of the cattle reared in Brazil
28 some parts would have gone to McDonald's. That is on
29 page 25.
30
31 The same applies to page 27 with the figures given for
32 early years. For example, 1984, say, 3,456 head of cattle
33 should read 34,566 head of cattle.
34
35 On top of page 34, when they give their brief consumption
36 as a percentage of the world total -- no, sorry, they were
37 saying in 1988 it was about 0.6 of the world total. In
38 fact, that would have meant that six per cent of cattle
39 raised in the world some parts of it would have gone to
40 McDonald's products.
41
42 MR. JUSTICE BELL: Where do you get that?
43
44 MR. MORRIS: I am trying to check this, because I am relying on
45 Mr. Rampton's figures.
46
47 MR. RAMPTON: Yes, but there is a difference between consumption
48 of head of cattle which are beasts and consumption of beef
49 which is in weight pounds, and the figures there are weight
50 pounds, and this seems to me to be a submission about the
51 facts of the case and nothing to do with the law at all.
52
53 MR. MORRIS: No... Yes, all I am saying is that if it is about
54 the amount of cattle physically needed for McDonald's then
55 I accept it has to be ten times the amount, percentages; if
56 it is just about the volume of actual physical raw beef,
57 then obviously Mr. Rampton's figures are right. I am not
58 saying he has wrong figures.
59
60 MR. JUSTICE BELL: The point is that you have made your point
