Day 095 - 02 Mar 95 - Page 51


     
     1        world.  That is why it was sent to Linda too.
     2
     3   Q.   But you are not all giving evidence?
     4        A.  Excuse me?
     5
     6   Q.   But you are not all giving evidence?
     7        A.  No, but she needs to be aware if it is a good thing.
     8        He thought it was good for me and to Linda to see.
     9
    10   Q.   Was the purpose of that because you did not have your own
    11        terms and definitions?
    12        A.  Finally you are asking some questions.  We have terms
    13        and definitions but you have to understand that the terms
    14        of one country.
    15
    16   MR. JUSTICE BELL:  The question was whether it was sent to you
    17        because you do not have your own terms and definitions?
    18        A.  Oh no.  We do not have terms and definitions for the
    19        entire welfare of animals.  We understand that the welfare
    20        of animals include everything here.  Here it is very
    21        limiting, some of the discussions that we had, OK, is
    22        limited to hunger and thirst.  So if you are feeding the
    23        wrong diet and as long as they do not go hungry or thirsty
    24        it is OK according to this.  For our purposes the need goes
    25        far beyond that.
    26
    27   MR. JUSTICE BELL:  Yes, very well.
    28
    29   MR. MORRIS:  You do not have in the US a written animal welfare
    30        policy such as this, do you?
    31        A.  Such as this one, no, we do not.
    32
    33   Q.   You do not have a written animal welfare policy?
    34        A.  I have seen a small statement, half a page, regarding
    35        animal welfare, the concept, but in detail, no, I do not
    36        see the need for being in detail because you can, even you
    37        can take check the (indecipherable) and tear it apart
    38        because many times it is not real, it is not merchantable
    39        and it is very limiting.
    40
    41   Q.   Just one final question.  The documents which you saw at
    42        Coope Montecillos and in Costa Rica McDonald's that you
    43        gave evidence on in December, something like 20 documents
    44        going back 10 years on the controversy that is part of this
    45        case, have you informed the Plaintiffs, the legal people,
    46        or whatever, where those documents were?
    47        A.  No, I have not.
    48
    49   Q.   Can you just say exactly where they were, where you saw
    50        them? 
    51        A.  Can you be more specific?  That was a long time ago. 
    52        You are talking about documents. 
    53
    54   Q.   You said when you were here in December that documents
    55        going back 10 years about Coope Montecillos?
    56        A.  Yes, I testified about that before.
    57
    58   Q.   Yes.  Could you say where they are?
    59        A.  I saw them in Costa Rica.  I saw them at the office in
    60        my office in Oak Brook.

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