Day 293 - 04 Nov 96 - Page 38


     
     1        leaflet; and I do not think you contend that it does.  It
     2        has been shown.
     3
     4   MR. MORRIS:   Well, first of all, I would say it does not say
     5        about cutting down the forests; it says that is the area
     6        needed to keep McDonald's supplied with paper; and that is
     7        another argument.  Secondly, even if you decided whatever
     8        the meaning is, the reality is that it is still a fact that
     9        McDonald's does require that amount of area of forest in
    10        terms that I have identified in my figures here -- which
    11        may even have been underestimates -- to maintain their
    12        packaging supplies.  That area of forest must be designated
    13        as plantation forest for commercial production in order
    14        that McDonald's can get their packaging.  That is the
    15        minimum area -- just as we are talking about the head of
    16        cattle issue.  So, whatever the interpretation of the
    17        leaflet, it is still, we would say, relevant evidence in
    18        this case -- which may or may not win the issue, but it is
    19        still a relevant thing that we ought to all get our heads
    20        around.  We certainly say that it is basic common sense.
    21
    22        Obviously, I have calculated that to be a total of -- with
    23        all those factorials, which are all quite basic common
    24        sense and not overestimated, in some cases
    25        underestimated -- something like 8,000 to 20,000 square
    26        miles of forest are required to be available so that
    27        McDonald's can get the kind of volume they need each year.
    28        If that was reduced by the factor of point 7, if point 7
    29        was removed, then it would be something like 200 square
    30        miles.  I am just trying to see. (Pause)  That is not with
    31        that additional point about "have only used some".  Point 6
    32        was clearly underestimated.  So, it would be 200 times an
    33        additional amount above the 1.4.  It should have been, say,
    34        1.8 or 1.9, if you count the whole of material not in
    35        production -- which would be actually something like an
    36        additional 28 percent, I think.  So, it would be something
    37        like 250 square miles.
    38
    39   MR. JUSTICE BELL:   Yes.  You have given me the material.
    40        I understand your calculation.  I will have to see what
    41        I make of it when I have heard Mr. Rampton as well.
    42
    43   MR. MORRIS:   Now, I think I may have a few other bits and
    44        pieces.
    45
    46   MR. JUSTICE BELL:   Shall we have a five-minute break there?
    47        Ms. Steel can think if she wants to say anything or tell me
    48        anything.
    49
    50                         (Short Adjournment) 
    51 
    52   MR. MORRIS:   Just on one point, on that page we were looking at 
    53        from Mr. Mallinson, where he says one thing at the top and
    54        one thing at the bottom, we feel that the fact that he had
    55        been in the frame of mind to look at it in a certain way,
    56        and, obviously, being a McDonald's witness and someone who
    57        was interested in defending the industry on this issue, we
    58        think it is more significant what he said as at the top of
    59        the page than what he said at the bottom of the page,
    60        because that would be in some cases an admission against

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