Day 068 - 16 Dec 94 - Page 29
1 Q. Will they be samples of the forms or will they be
2 summaries, or what will they be?
3 A. They will be both. It is up to them to make summaries.
4
5 Q. How long do they go back till?
6 A. I have no idea. I do not know.
7
8 Q. You saw them?
9 A. The ones that I saw, I said they go back, when I asked
10 for them, a few months.
11
12 Q. So how do you know what is happening, for example, in the
13 1980s; or do you know what was happening in the 1980s?
14 A. I do not know. I have not seen records from 1980 prior
15 to my arrival.
16
17 Q. So did, in fact, McDonald's know, prior to your arrival,
18 what the sources of their beef were?
19 A. Did they know?
20
21 Q. Yes -- in Costa Rica?
22 A. From my discussions that I have had, yes.
23
24 Q. How did they know that, then?
25 A. That they had visited the plant. We developed the
26 plant, the process; and, again, Mr. Ray Cesca, who has been
27 more involved in the rainforest, can provide you with more
28 information, more detailed information.
29
30 MR. MORRIS: Right. But you do not know then that -- what do
31 you know about -----
32
33 MR. JUSTICE BELL: If I might suggest, all you do is keep
34 provoking him into giving hearsay evidence.
35
36 MR. MORRIS: I understand that. I am trying to see what he
37 knows.
38
39 MR. JUSTICE BELL: It is quite clear that Dr. Gomez Gonzales
40 does not, of his own direct knowledge, about the 1980s.
41 Why push him into saying that someone else has told him
42 something about that, which may very well, in so far as it
43 is evidence at all, be adverse to your case?
44
45 MR. MORRIS: I do not mind if something is adverse to my case if
46 it is the truth. The point is, I am trying to
47 establish -----
48
49 MR. JUSTICE BELL: The whole point is, we do not know whether it
50 is the truth, if it is just what someone else has told him.
51
52 MR. RAMPTON: My Lord, Mr. Morris does have a problem. He may
53 not think that he does. He has two problems: the first is
54 that hearsay evidence of what a person who is abroad has
55 told somebody is admissible in certain circumstances.
56
57 The other, and more important, point is this: Mr. Morris
58 seems to think this is some kind of public inquiry and that
59 he, in some sense, is counsel to the tribunal. I have sat
60 here very patiently for the whole of this morning. I do
