Day 087 - 10 Feb 95 - Page 44
1 USA is in the hands of secondary or even tertiary suppliers
2 of McDonald's in Germany. What documents the farmers who
3 form the Raffeisen co-operative might have I know not, but
4 it is no obligation of my clients to find out.
5
6 MR. JUSTICE BELL: Do you have ready to hand the Professor
7 Doctor's reference?
8
9 MR. RAMPTON: Yes, my Lord. He has made two statements. He is
10 at the moment I think not even a Civil Evidence Act
11 statement because it is our intention to bring him over.
12 He will need to be interpreted. He is volume yellow XI,
13 numbers 3 and 4. They have, I think, been translated. He
14 is not a McDonald's person. I think he is engaged by, not
15 employed, the co-operative, not the meat suppliers, but I
16 am not sure about that.
17
18 MR. JUSTICE BELL: Those taken together with the ones you listed
19 are all the matters I had on my 27, the remainder being
20 ones where I had either heard you in reply or given some
21 indication of what should happen, which I can repeat if
22 necessary, or where a solution was in the pipeline.
23
24 MR. RAMPTON: I can deal with almost anything at short notice if
25 required. My Lord, if there is time this afternoon, which
26 I believe there is, it is entirely a matter for Lordship,
27 I would like the opportunity this afternoon to deal with
28 the question of the Defendants' employment witnesses.
29 I have some concrete things to say about them.
30
31 MR. JUSTICE BELL: Do you want to reply to these matters which
32 you are going to reply to?
33
34 MR. RAMPTON: If your Lordship would like me to I certainly can.
35
36 MR. JUSTICE BELL: Then if Mr. Morris wants my ruling on it
37 I can go away and think about it and give it in due course.
38
39 MR. RAMPTON: Certainly, my Lord. Before I do that may I hand
40 out what I thought I always had and I was for once in my
41 life right about, a copy of the Bowes' brochure I had in
42 the boot of my car. I will give that to the Defendants to
43 feast their eyes on over the weekend.
44
45 For the purposes of Oregon and Silver Spring in 1982 and
46 1987 respectively, I ask your Lordship to look at (this is
47 in the context of an application for discovery by the
48 Defendants) volume yellow XII at tab 14. My Lord, the
49 allegation is at the top of page 4 of tab 5 of the abstract
50 of pleadings; it is the first paragraph on the page. It is
51 useful, in my submission, in the light of the application
52 for discovery in relation to this issue to see what is
53 alleged and then to compare it with what Mr. Rummel says in
54 paragraph 3 of his statement. That is Oregon. Silver
55 Spring is at the bottom of page 3 of the pleading and in
56 paragraph 2 of Mr. Rummel's statement.
57
58 MR. JUSTICE BELL: Yes.
59
60 MR. RAMPTON: My Lord, the first thing to observe, and I do not
