Day 287 - 25 Oct 96 - Page 16


     
     1        in Germany was nothing, or next to nothing, of the source
     2        of cattle, farms where the cattle were raised in Germany
     3        for their beef supplies up to about 1990.  Basically, I
     4        think he said, Gonzales concluded that there was only about
     5        80 percent traceability, now, at that time that he gave his
     6        evidence.  Mr. Cesca on page 51, day 224, accepted that.
     7
     8        Then on day 225 there is the main evidence on soya
     9        from-----
    10
    11   MR. JUSTICE BELL:   What did you say the percentage of
    12        traceability was?
    13
    14   MR. MORRIS:   80 percent.  That was Dr. Gonzales' figure.  I
    15        will just check that again.
    16
    17   MR JUSTICE BELL:  No, there is no need to.  I thought I may have
    18        misheard.
    19
    20   MR. MORRIS:   Yes.  Then, on day 225, pages 6 to 21, is
    21        Mr. Cesca's cross-examination about the soya issue, the
    22        main block of it.  On page 7, lines 27 to 34, he recognises
    23        the use of soya in Europe is seasonal.  Sorry, he does not
    24        recognise that.  He says that his position is "... there is
    25        a dry and wet season in just about every country, so if
    26        that is what you mean, yes."  What he is saying there is
    27        that he recognises that in terms of feed supplies virtually
    28        every country has a dry and wet season, which is just about
    29        every country, he says, would probably require feed of some
    30        kind, and in Europe that entails soya, if that is what we
    31        are talking about.
    32
    33        Then he was questioned about the soya feed for steers as
    34        opposed to cows.  When I say 'steers', I mean steers and
    35        bulls, anything different from cows.
    36
    37        On page 9, he deals with the matter that the figures by
    38        Schumm are all related to cows and he would not give a
    39        figure on what the steers would consume, or bulls would
    40        consume, but he does say he does agree with the letter from
    41        McDonald's to Frank Swurts that is referred to in our
    42        statement of Frank Swurts, which is a Civil Evidence Act
    43        notice for us, and that the letter from McDonald's said,
    44        "The percentage used by dairy is irrelevant compared to
    45        the amount used in fattening bulls."  I said to him, "So it
    46        is some substantial amount greater?"  Answer, "Yes, I mean,
    47        that makes sense to me, what you just read."  No doubt
    48        because it came from McDonald's.
    49
    50        The point I am making is that the fattening of steers and 
    51        bulls anywhere in Europe where anything other than cows are 
    52        used for McDonald's products, then the overall picture is 
    53        that there will be vastly greater amounts of soya, and, at
    54        certain times of the year, that is likely to come from
    55        Brazil, Brazil being one of the major exporters and
    56        responsible for something like 30 percent of all soya
    57        imports into Europe, whatever the figures were that we
    58        referred to before.  It is also helpful for -- sorry.  I am
    59        definitely going to finish by one.
    60

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