Day 286 - 24 Oct 96 - Page 28


     
     1
     2   MR. JUSTICE BELL:   Yes.
     3
     4   MR. MORRIS:   And the Tozey map, we would say obviously we are
     5        concerned about all tropical forests including what may be
     6        a misnomer, dry forest, which is in fact, and evidence was
     7        heard on that, as being more of the character of forest
     8        that we know and understand here.  But in terms of moist
     9        forests, and remember that John Carriere said in fact that
    10        the sub-categories in the life zones of rainforest
    11        definition are not as species rich as the wet forests, and
    12        it seems, without playing silly games all round, that while
    13        we are concerned with all forest types, all the moist
    14        forest types have an unusual character which is special to
    15        tropical regions.  In fact, even the dry forests are
    16        defined on the Tozey map as tropical dry forests, so they
    17        have a particular tropical character.
    18
    19        And the whole of the San Isidro region, however far you
    20        want to draw the line, left/right, north or south, is all
    21        moist forest type, in terms of life zone characteristics.
    22        It is moist forest.  The majority of it is wet forest or
    23        pre-montain or lower montain rain, or lower montain wet or
    24        whatever.  The point being that it is all defined, as it
    25        was defined for Mr. Cesca, as rain or wet forest.
    26        And that area, McDonald's have admitted that twenty percent
    27        of their supplies came from that area.
    28
    29        And the next map I was going to refer to, of course, are
    30        the deforestation, progressive deforestation maps of which
    31        the most detailed -- well, there was two; there was the one
    32        supplied by John Carriere and the one in the book, Tropical
    33        Rainforests Yesterday Today and Tomorrow, page 167, which
    34        should be behind his statement, although it was served at a
    35        different time.
    36
    37   MR. JUSTICE BELL:   Behind John Carriere's statement?
    38
    39   MR. MORRIS:   There was one behind John Carriere's statement
    40        that he had written on with arrows which looked like this.
    41        But there was another one, which was an extract from a book
    42        which I think we worked from because it was more detailed,
    43        there was a series of five rather than three progressive
    44        deforestation maps.
    45
    46   MR. RAMPTON:   My Lord, there were, I think, indeed three maps,
    47        all produced by the defendants.  One was by Sader and
    48        Joyce.  I cannot give the reference because they are the
    49        defendants' documents.
    50 
    51   MR. JUSTICE BELL:  What was the first name again? 
    52 
    53   MR. RAMPTON:   Sader, it is S-a-d-e-r.  And Joyce was the second
    54        name.  Showing all the relevant areas which have been
    55        deforested at different dates, including up to 1961.  That
    56        does not give any specificity of type of forest.
    57
    58        Then there are the maps from the Tropical Science Centre
    59        book to which Mr. Morris has been referring, the Tozey
    60        maps, which show more or less the same thing.  Then there

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