Day 068 - 16 Dec 94 - Page 48


     
     1        government that would know.
     2
     3   Q.   What about minutes of company meetings, or something, where
     4        this was discussed, where the whole issue was gone into;
     5        have you seen things like that?
     6        A.  Can you repeat the question?
     7
     8   Q.   When it became a controversy, the company must have
     9        discussed it.  They may have said, you know -- well, they
    10        may have said anything, I do not know.  But would you have
    11        seen minutes of meetings which made you feel that they are
    12        taking the situation seriously?
    13        A.  One of the reasons -- I know for a fact, and it has
    14        been my experience, that we take any potential allegation
    15        very seriously.
    16
    17   MR. JUSTICE BELL:  Yes.  All you are being asked is whether you
    18        have seen any documentation which suggested that any
    19        independent inquiry was made, by which I assume Mr. Morris
    20        means was anyone outside the company asked to look into it.
    21
    22   MR. MORRIS:  Or that it was discussed by the company at top
    23        level?
    24        A.  I have stated before that I have not seen any evidence,
    25        any documented evidence, which would include minutes, on
    26        that particular issue.  I have heard, though, the
    27        conversations, and I know that we do not have room to keep
    28        all of the minutes that we produce in the last 10 years.
    29        In addition to that, I was not at the company in those
    30        years.
    31
    32   Q.   So when you were making your searches for information so
    33        that you could give evidence on oath here today about the
    34        true situation, did you find any specifications on the
    35        areas that pre-dated the mid-1980's, any specifications
    36        that either said "Coope Montecillos is not to export beef
    37        to other McDonald's companies", or specify the sources that
    38        were prohibited within Costa Rica for the purchase of beef
    39        by Coope Montecillos, specifications of Coope Montecillos
    40        or to Coope Montecillos?  Let us concentrate on the second
    41        one; forget the exports for the moment.  Have you seen any
    42        specifications which have said clearly to Coope Montecillos
    43        where their sources of beef should or should not come from,
    44        that pre-date, say, 1985 or whatever?
    45        A.  I am not sure if I understand your question.  I am
    46        going to repeat it the way I understand it.  Your question
    47        is, have I seen any specifications -- I take it food
    48        specifications or any?
    49
    50   MR. MORRIS:  Any specifications. 
    51 
    52   MR. JUSTICE BELL:  It was a very long question.  You started 
    53        with this company in 1991.  You are being asked whether you
    54        have seen any documents before 1985 which indicated that
    55        McDonald's had a policy not to use beef which came from a
    56        rainforest area.
    57        A.  OK.
    58
    59   Q.   Just say "yes" or "no", first of all?
    60        A.  No, no, I have not.

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