Day 093 - 28 Feb 95 - Page 48


     
     1   Q.   On the right-hand column, can you just explain the -- you
     2        have not checked these before?
     3        A.  No, I told you, I have not requested -- I have seen
     4        them but I have not requested this information before.
     5        I do know that they exist.  That is why I asked for them.
     6
     7   Q.   So environment/index.html">litter conditions, dry, wet, caked, caked under water --
     8        how often is the environment/index.html">litter wet?
     9        A.  I do not know what you mean by "wet".
    10
    11   Q.   Whatever they mean by "wet"?
    12        A.  I do not know.  I cannot tell you a percentage of
    13        times, I do not know.
    14
    15   Q.   How often is the environment/index.html">litter caked?
    16        A.  I do not know.  Will you see it -- yes.  I cannot tell
    17        you once every three days or X percentage, I do not know.
    18
    19   Q.   That can lead to problems with Hock Burn and things like
    20        that, can it not?
    21        A.  It may, if the animal decides to just stay there, sit
    22        there, but that does not mean that leads to that.
    23
    24   Q.   Have you seen that happen?
    25        A.  No.  Tysons has one of the best records with this.
    26        I have not seen problems with that.
    27
    28   Q.   How long is the food left in the bins?
    29        A.  Oh, it is continuously replaced.  It is moved to
    30        another when -- it is continuous, it is not left there.
    31
    32   Q.   But it sometimes goes mouldy?
    33        A.  Oh, no.
    34
    35   Q.   It is listed there as a possibility?
    36        A.  It is a possibility they see something that for
    37        whatever reason that is stuck on somewhere, but no.  I have
    38        never seen it.
    39
    40   Q.   Wild birds, what is that?  Is that birds that have got into
    41        the broiler houses?
    42        A.  It could be, yes.  That is what it is.
    43
    44   Q.   There is the ammonia level there, what would the company do
    45        if the ammonia level was high registered there?
    46        A.  Move to another house.
    47
    48   Q.   Move all the chickens to another house?
    49        A.  Yes.  I do not know, but again I do not want to
    50        speculate.  I have never seen it done, so it is not fair 
    51        for me to speculate. 
    52 
    53   Q.   Could you turn to the Defendants' Second Supplementary list
    54        of documents, or ----
    55        A.  Can you direct me to that?
    56
    57   Q.   It will be one of the blue files on the top row -- it might
    58        be Supplementary List No. 2?
    59        A.  Tab number?
    60

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