Day 067 - 15 Dec 94 - Page 36
1 pile of documents there, official documents, and that was
2 the only one that they sought to make a copy of to give to
3 us.
4
5 MR. RAMPTON: No, my Lord. The other documents, I happen to
6 know the identity of some of them, because Dr. Gomez
7 Gonzalez has shown them to me before he started giving
8 evidence. They are, in effect, a witness pack compiled by
9 my solicitors with the help of the American lawyers for the
10 witness to prepare himself.
11
12 MR. JUSTICE BELL: I would not infer, I would not have thought
13 there was anything strange that two documents out of a
14 whole number in a briefcase are discoverable, or that 98
15 per cent of them are discoverable. It must entirely depend
16 upon what is in the briefcase.
17
18 MR. MORRIS: So, Mr. Gonzalez, did you manage to find a
19 reference to animal welfare and animal welfare policy?
20 A. Not yet.
21
22 Q. In your briefing pack and your general briefing, did you
23 manage to find when you were preparing for this case any
24 document which identified a McDonald's Corporation policy
25 on animals, animal welfare?
26 A. The only thing that I identified is what I mentioned
27 before regarding, that our suppliers must follow all laws
28 and regulations, which include the Humane Slaughter Act,
29 but I did not specifically found anything in this pink
30 file, a specific written policy, regarding the Humane
31 Slaughter Act.
32
33 Q. The Humane Slaughter Act is only applicable in the United
34 States of America, is it not?
35 A. It is a law and regulation that is applicable in the
36 United States of America, that is correct, but if you look
37 at our specification it implies that any manufacturer of
38 beef outside of the US must follow the same regulation.
39
40 Q. It does not say that, does it?
41 A. Yes, it does, sir.
42
43 Q. What you read out: "When doing business outside of the
44 United States of America manufacturers must comply with all
45 applicable food laws and regulations"?
46 A. That is exactly what it says.
47
48 Q. It is the ones that apply in that particular country?
49 A. It says applicable under our corporate policy.
50 McDonald's Corporation will follow the same policies and
51 guidelines that we are subjected as a company in the United
52 States.
53
54 Q. It does not say that, though, does it? You have not got
55 anything about a corporate policy on animal welfare?
56 A. It says "all applicable laws and regulations".
57
58 Q. So when they read that, the small print, each supplier,
59 each of your thousands of suppliers around the world, has
60 to interpret what you mean by "applicable" and guess what
