Day 292 - 01 Nov 96 - Page 36


     
     1        about that?  You have made your point about it.
     2
     3   MR. MORRIS:   Yes.  So this part in parentheses, which, as I
     4        said, I have not looked through the whole of the rest of
     5        the pamphlet, but I don't think there is any equivalent
     6        section in the entire pamphlet that is in parentheses in
     7        that way.  In fact, I think we can say that there is not
     8        anywhere in the pamphlet something like that.
     9
    10        So clearly the impression that the person reading this
    11        would be given is that this is branching off on a train of
    12        thought which, while relevant to this section of the
    13        pamphlet, because it could not fit in anywhere else,
    14        clearly is separate from the issue, the immediate specific
    15        issue, which is about tropical forests, and of course that
    16        the use of the word "forests" is referred to there as
    17        well.
    18
    19        The other thing is we would argue -- obviously it is
    20        talking about all forests, because it says forests, but
    21        also, although the mind of the person writing this pamphlet
    22        is in some ways irrelevant, certainly it is our
    23        understanding it was based upon the estimate made by Bruce
    24        Hannon some years before.  In fact, the words are virtually
    25        identical from the extract of what he said in the San
    26        Francisco Examiner, which I can't remember where the
    27        document is.
    28
    29   MR. JUSTICE BELL:  You need not worry, because I have that in
    30        mind.
    31
    32   MR. MORRIS:   In fact, in our pleadings it is pleaded very
    33        badly, it was not what he said in the San Francisco
    34        Examiner; what he said in the San Francisco Examiner is, as
    35        far as we are concerned, absolutely accurate.
    36
    37        We note the words "to keep them supplied with paper for one
    38        year", and that is very careful wording to imply an ongoing
    39        usage, and the same considerations would apply to, for
    40        example, the head of cattle needed to be raised for
    41        McDonald's benefit.  We have to understand that if
    42        McDonald's only take 10 percent of a cow, that cow still
    43        has to be raised for the companies that use the various
    44        parts of it because it cannot be raised just as a 10
    45        percent animal.  So that is common sense, we would say.
    46
    47        Now, as regards the 'do not be fooled by McDonald's saying
    48        they use recycled paper or a tiny percent of it is', it
    49        does not say there that they are lying.  It does not say,
    50        as McDonald's claim, that they are lying when they claim to
    51        use recycled paper; it says, 'do not be fooled', i.e. it
    52        says, 'do not be fooled' i.e., do not just take everything
    53        at face value, do not just see the side of the story that
    54        they want to put to you, what is the reality?   It says,
    55        only a tiny percent of it is, i.e., when McDonald's say
    56        they use recycled paper it may in fact only contain a tiny
    57        percent of recycled content, or if they say in general,
    58        'Oh, we use recycled paper' then people have to
    59        investigate and say, 'Well, exactly what percentage of
    60        their paper is recycled? '

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