Day 067 - 15 Dec 94 - Page 64


     
     1        question again, I suggest you put it in some more specific
     2        way to test it like that.
     3
     4   MR. MORRIS:  OK.
     5
     6   MR. JUSTICE BELL:  You might ask, for instance, whether the
     7        letter, the one which he said it was the latest one,
     8        I think by that Dr. Gomez Gonzalez meant the one going
     9        furthest back, because clearly the one 10 years ago could
    10        not have been the latest in time.  If you like, ask him
    11        whether that was just referring to the state of affairs as
    12        it then was, or purported to refer further back, do you see
    13        what I mean, about what had happened in the past, or
    14        whether he can really remember what the contents of the
    15        letter were without actually having it in front of him.
    16
    17   MR. MORRIS:  Let me, first of all, I am not trying to intimidate
    18        the witness.
    19
    20   MR. JUSTICE BELL:  Start again then.
    21
    22   MR. MORRIS:  I am trying to identify what I am trying to find
    23        out, because it is up to me what questions I ask.  I am not
    24        saying that he is deliberately avoiding answer the
    25        question.  I am just trying to clarify what I am trying to
    26        ask you.  (To the witness):  I am trying to clarify, have
    27        you seen any documentary evidence before, say, the letter
    28        of 1983 or 1984, can you recall seeing any documentary
    29        evidence, either in Coope Montecillos' records or in the
    30        McDonald's Costa Rica records, which convinced you before
    31        that oldest letter that you have seen that they were not
    32        exporting to any other McDonald's in the rest of the world?
    33        A.  Before that time I have not seen any written evidence
    34        but, like I said before, I have communicated, talked,
    35        discussed and explored that possibility through other
    36        means, through our people and our suppliers in the United
    37        States as well as our restaurants operations.  So, I have
    38        not seen any written confirmation or verification prior to
    39        that time, but I have talked to numerous people which will
    40        give me enough confidence to say -----
    41
    42   MR. JUSTICE BELL:  You have said that before.  The question was
    43        just about whether you had seen written -----
    44        A.  No, I have not.
    45
    46   MR. MORRIS:  Coope Montecillos who you work closely with over
    47        the last year, yes?  You have been in Costa Rica for a long
    48        time?
    49        A.  I have been in Costa Rica for the last three and a half
    50        years.  On numerous occasions I have worked with Coope 
    51        Montecillos as well we are currently developing a new 
    52        supplier called Procarne. 
    53
    54   Q.   Just to go from after 1983, you say you have seen something
    55        like 20 or 30 documents about this issue of not exporting
    56        to any other McDonald's; is that correct?
    57        A.  You said in 1993?
    58
    59   Q.   No, sorry, documents that date from 1983/4 up to now, you
    60        have seen twenty or 30, you said, something like that, more

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