Day 158 - 19 Jul 95 - Page 18
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2 MR. MORRIS: That is what it says, yes.
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4 MR. JUSTICE BELL: But we are looking at what the evidence is so
5 far.
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7 MR. MORRIS: Yes.
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9 MR. JUSTICE BELL: You may say there is evidence to the
10 contrary, I do not know. But I am looking at this.
11 McDonald's raw materials suppliers.
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13 MR. MORRIS: It lists the seven red blobs there.
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15 MR. RAMPTON: I can tell your Lordship that the first four in
16 the left-hand column are the four blobs north of Sao Paulo;
17 the three in the right-hand column are all south of
18 Sao Paulo on the Uruguayan border. I will in due course
19 give your Lordship a marked map showing precisely the
20 location in legible form of each of these sources of beef.
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22 MR. JUSTICE BELL: What is the -----
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24 MR. MORRIS: The triangle is McDonald's meat processing plants.
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26 MR. JUSTICE BELL: What does it say underneath that?
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28 MR. MORRIS: "Lines connect McDonald's raw materials suppliers
29 to meat processing plant".
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31 If we go back to the Vesty -----
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33 MR. JUSTICE BELL: Let us go back to that in five minutes.
34
35 (Short Adjournment)
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37 MR. JUSTICE BELL: Yes?
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39 MR. MORRIS: Obviously, our aim is now to demonstrate that we
40 have a reasonable belief that what we have pleaded is
41 correct. The Vesty letter -- which is obviously relevant
42 to whether it is 80 or 110 tonnes exported to the UK in the
43 1980s -- in the second paragraph, it says: "200,000 head
44 of cattle killed there annually for Barretos plant" --
45 which is by McDonald's -- "are bred on the natural scrub
46 plains of the states of Minas Gerais and Mato Grosso and
47 also on the very extensive flood plain of the
48 River Paraguay."
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50 The Minas Gerais and Mato Grosso -- Goias is the most
51 northernmost supply plant for that region; Mato Grosso is
52 the area that includes all the horizontal lines; and
53 "Minas" is, presumably, Minas Gerais -- I cannot see any
54 other Minas to distinguish it -- which is on the
55 easternmost point next to what we could call the third
56 blob.
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58 The flood plain of the River Paraguay, on this map -- well,
59 Paraguay is a whole region itself; I am just trying to
60 identify the flood plains. I think both parties have
