Day 158 - 19 Jul 95 - Page 19


     
     1        another map and, certainly, Mrs. Brinley-Codd has a very
     2        excellent one.  Is it possible I could just borrow it?
     3        I wanted to check the flood plain and River Paraguay.
     4
     5        The River Paraguay runs through, just slightly right of
     6        centre, in a vertical direction through the region, through
     7        the country of Paraguay, which, on the map we have in front
     8        of us -- you can see the river going between the "u" and
     9        the "a" of the word "Paraguay".
    10
    11   MR. JUSTICE BELL:  I can see that.  Where does it go to the
    12        north of that?  Does it run along the border between Brazil
    13        and Paraguay and Brazil and Bolivia, or where?
    14
    15   MR. MORRIS:  It does.  It runs along the border, and then goes
    16        right up into Mato Grosso itself -- not Mato Grosso Do Sul,
    17        but Mato Grosso itself -- and peters out.  Let me just
    18        check this a little bit, to be as accurate as we can be.
    19        It splits up at a place call Caserene, but you cannot see
    20        that on this map.  It sort of splits up round about where
    21        the most western-most blue square is.  It sort of continues
    22        north of that, but it sort of spreads out into three or
    23        four other different rivers.  That, presumably, is part of
    24        the flood plain.  Anyway, evidence will be given about that
    25        when we call our expert witness.
    26
    27   MR. JUSTICE BELL:  What is the scale of this, as I have it
    28        reproduced before me?
    29
    30   MR. MORRIS:  I do not know.  Do the Plaintiffs know?
    31
    32   MR. JUSTICE BELL:  I only ask because the last sentence in that
    33        second paragraph says:  "All the areas are well within
    34        1,000 kilometres of Barretos"; and if Barretos is --
    35        totally illegible on my copy -- is the writing immediately
    36        beneath the red circle with a dot in it, which is covering
    37        the "G" of the Gerais, if that is Barretos, then it might
    38        be relevant to know how far 1,000 kilometres goes.
    39
    40   MR. MORRIS:  Last night, we worked out that 1,000 kilometres was
    41        something like, from Sao Paulo, where the processing plant
    42        is, down to what you can see, a town called Alegre on the
    43        coast.  That is something like the equivalent of 1,000
    44        miles.  It is about a thumb -----
    45
    46   MR. JUSTICE BELL:  That is 1,000 miles or 1,000 kilometres?
    47
    48   MR. MORRIS:  Sorry, 1,000 kilometres, which is my thumb; and, by
    49        that definition, 1,000 kilometres would take us just inside
    50        the Mato Grosso horizontal area, and in a radius ----- 
    51 
    52   MR. RAMPTON:  My Lord, the map which I have done, and which 
    53        Mr. Riley has kindly now copied, has drawn on it an
    54        800 kilometre circumference.  It will come back, I hope, in
    55        a moment.
    56
    57   MR. MORRIS:  Certainly, by our calculations, it goes into
    58        Mato Grosso (as indicated in the letter, of course) and
    59        beyond Goias.
    60

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