Day 068 - 16 Dec 94 - Page 58
1 first page -- it is Jill Chang. She is our McDonald's
2 country purchasing manager.
3
4 Q. In Taiwan?
5 A. In Taiwan.
6
7 Q. So she filled out this form. I notice that the English, in
8 general, is very good, is it not?
9 A. Yes.
10
11 Q. "Covered yards" and "sprinklers" or "springlers". Then
12 under: "Are animals rested prior to stunning and
13 slaughtering?" "Yes, minimum 24 hour". That seems to be
14 very colloquial in English. So, the person doing this
15 seems not to have a problem with English, do they?
16 A. That is incorrect. I know Jill. I have talked to her
17 and, if you look at this form, it is not, it is not easy to
18 say, write -- "Yes, min. 24 hours", it does not take a lot
19 of English to write that. It does take a considerable
20 mental effort for a person who speaks, I think it is,
21 Mandarin language.
22
23 MR. JUSTICE BELL: What are you suggesting, Mr. Morris?
24
25 MR. MORRIS: I am suggesting that when they say "Product
26 exported to (country), Japan, USA, Taiwan", yes, that is
27 what they are exporting to McDonald's in those countries,
28 for McDonald's use, that is.
29
30 MR. JUSTICE BELL: What do you say about that?
31 A. That is thoroughly incorrect.
32
33 MR. MORRIS: How do you know?
34 A. Because I know. I have been in all zones. I have been
35 in those areas -- I know. That is not, it does not make
36 any sense, even economically, to do that, to move product
37 from Australia to Taiwan to the United States when it is
38 cheaper to have it in the USA in the first place.
39
40 Q. It does not say, does it, "through Taiwan"? It says that
41 is where this plant is exporting to, Latchley Meats,
42 Australia ---
43 A. OK.
44
45 Q. -- is exporting to Japan.
46 A. OK. They made a mistake. They do not export to
47 Australia. They import raw materials from Australia.
48
49 MR. JUSTICE BELL: No. What Mr. Morris is suggesting is that,
50 on the face of it, the information which has been put on
51 your questionnaire means that Latchley Meats export beef
52 from Australia to Japan, to the USA, and to Taiwan ---
53 A. No.
54
55 Q. -- first of all and, secondly, he suggests that it means
56 they not only export Australian beef to those countries but
57 to McDonald's in those countries, that is his suggestion.
58 A. OK. They do export raw materials to Japan, to the US
59 and Taiwan, that is correct. They do not export, nor do
60 they have the capability, to process finished patties so,
