Day 158 - 19 Jul 95 - Page 18


     
     1
     2   MR. MORRIS:  That is what it says, yes.
     3
     4   MR. JUSTICE BELL:  But we are looking at what the evidence is so
     5        far.
     6
     7   MR. MORRIS:  Yes.
     8
     9   MR. JUSTICE BELL:  You may say there is evidence to the
    10        contrary, I do not know.  But I am looking at this.
    11        McDonald's raw materials suppliers.
    12
    13   MR. MORRIS:  It lists the seven red blobs there.
    14
    15   MR. RAMPTON:  I can tell your Lordship that the first four in
    16        the left-hand column are the four blobs north of Sao Paulo;
    17        the three in the right-hand column are all south of
    18        Sao Paulo on the Uruguayan border.  I will in due course
    19        give your Lordship a marked map showing precisely the
    20        location in legible form of each of these sources of beef.
    21
    22   MR. JUSTICE BELL:  What is the -----
    23
    24   MR. MORRIS:  The triangle is McDonald's meat processing plants.
    25
    26   MR. JUSTICE BELL:  What does it say underneath that?
    27
    28   MR. MORRIS:  "Lines connect McDonald's raw materials suppliers
    29        to meat processing plant".
    30
    31        If we go back to the Vesty -----
    32
    33   MR. JUSTICE BELL:  Let us go back to that in five minutes.
    34
    35                       (Short Adjournment)
    36
    37   MR. JUSTICE BELL:  Yes?
    38
    39   MR. MORRIS:  Obviously, our aim is now to demonstrate that we
    40        have a reasonable belief that what we have pleaded is
    41        correct.  The Vesty letter -- which is obviously relevant
    42        to whether it is 80 or 110 tonnes exported to the UK in the
    43        1980s -- in the second paragraph, it says:  "200,000 head
    44        of cattle killed there annually for Barretos plant" --
    45        which is by McDonald's -- "are bred on the natural scrub
    46        plains of the states of Minas Gerais and Mato Grosso and
    47        also on the very extensive flood plain of the
    48        River Paraguay."
    49
    50        The Minas Gerais and Mato Grosso -- Goias is the most 
    51        northernmost supply plant for that region; Mato Grosso is 
    52        the area that includes all the horizontal lines; and 
    53        "Minas" is, presumably, Minas Gerais -- I cannot see any
    54        other Minas to distinguish it -- which is on the
    55        easternmost point next to what we could call the third
    56        blob.
    57
    58        The flood plain of the River Paraguay, on this map -- well,
    59        Paraguay is a whole region itself; I am just trying to
    60        identify the flood plains.  I think both parties have

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