Day 287 - 25 Oct 96 - Page 08


     
     1        definitions of his shading.
     2
     3   MR. JUSTICE BELL:  Yes, I understand that.
     4
     5   MR. MORRIS:   If you remember, we got a better version of the
     6        Cotter map and the shading, the two shading types, sent to
     7        us by Dr. Cotter.
     8
     9   MR. JUSTICE BELL:  Do not worry about that.
    10
    11   MR. MORRIS:   Right.  It will be our opinion, and the opinion of
    12        our experts, that the Cotter map was the minimum defined
    13        areas, and our witnesses all said that if anything it was
    14        too limited in its area of definition.
    15
    16   MR. JUSTICE BELL:   Just pause there.  (Pause).  Yes.
    17
    18   MR. MORRIS:   We would say all this is not surprising anyway,
    19        because through McDonald's own admission, through the
    20        general manager of Procasa supplier, the statement from
    21        him, Rolando Roblez -- I am sorry, I do not have the
    22        reference, it is McDonald's witness Civil Evidence Act
    23        notice statement, when he says how the cattle slaughtered
    24        to supply McDonald's in Guatemala come from ranches in
    25        regions in Southern Guatemala.  This has been the case
    26        since Procasa started operations.  These regions would be
    27        forested in the '40s and early '50s.  And that is
    28        immediately following a sentence about the rainforest, and
    29        that is in paragraph 3 of his statement, and he can only be
    30        talking about rainforest.
    31
    32        And it is further backed up in a letter of Alvaro Cofino,
    33        this is Mr. Cesca, in that series of letters from Costa
    34        Rica and Guatemala.  Mr. Cesca dealt with it in his
    35        evidence, where he says -- the last paragraph on page 1 of
    36        that letter, and I will probably got the reference in the
    37        Cesca transcripts in a minute: "From where the meat plant
    38        buy their cattle used to be rainforest but was destroyed at
    39        the end of the last century", he says.  The point being
    40        that that is what he says the government advised him.
    41
    42        I think the important point about that hearsay opinion is
    43        that it is an admission that the area we are talking about
    44        is rainforest, the area where they get their cattle used to
    45        be rainforest.  And the only question is, when was it
    46        deforested.  He provides a map identifying various areas
    47        upon which Mr. Cesca based his McDonald's map, which he has
    48        used in this case.
    49
    50        So the only expert opinion we have heard about the area of 
    51        deforestation and the type of deforestation is from the 
    52        work of Cotter and Nations, and the admissions by 
    53        McDonald's witnesses on that subject.
    54
    55        Mr. Cesca was asked on day 222, page 35 about IGG, at the
    56        bottom of the page, he was asked about the suppliers who we
    57        had originally pleaded on Guatemala, in the late '70s, mid
    58        '70s, he presumed the beef that supplied them came from
    59        the same areas as the ones we are talking about here.  That
    60        is what he says on the top of page 36.  And he presumed

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