Day 068 - 16 Dec 94 - Page 33


     
     1        A.  Yes.  McDonald's does not buy -- no, we do not import
     2        products from Brazil, and it is not only because of our
     3        public relations that may be affected, but it is primarily
     4        because Brazil is limited in their export capabilities
     5        because the disease that is called hoof and mouth disease,
     6        which is recognised by the United Nations and world health
     7        organisations.  So you cannot import to the US, you cannot
     8        import product from Brazil.
     9
    10   Q.   But McDonald's in other countries have bought beef from
    11        Brazil in the past?
    12        A.  As far as I know, heard or discuss, we have never even
    13        mentioned that we are looking at moving product from Brazil
    14        into any other country.
    15
    16   Q.   So, in fact, going back from before your time, from what
    17        you have been told by other people, the policy has been
    18        never to buy beef from Brazil, has it?
    19        A.  No, sir.  As I mentioned before, our policy has always
    20        been, as far as I can remember, as far as I have heard, not
    21        to use any beef from any areas that are considered
    22        rainforest.  Brazil has areas that is rainforest; it also
    23        has areas that is not rainforest.  We do not state on our
    24        policy that we condemn a country because a part of that
    25        country is a rainforest.
    26
    27   Q.   But, as far as you know, no other McDonald's, from what you
    28        have been told, has bought beef from Brazil ever, from
    29        Brazil?
    30        A.  From McDonald's to McDonald's, and from McDonald's to
    31        Brazil, that is a correct statement (sic).
    32
    33   Q.   So if, hypothetically, someone had bought some beef from
    34        Brazil, from another McDonald's, from McDonald's anywhere,
    35        had bought beef from Brazil, if they were saying it was not
    36        from recently deforested rainforest areas, that would apply
    37        to not deforested since the operation started in Brazil,
    38        would it?  Would it be the same standard as the companies
    39        in that country itself?  Do you see what I am saying?
    40        A.  That is correct.  They will follow, if they could,
    41        which has not been for years, and I would hate to speculate
    42        on an issue where we spend an enormous amount of efforts to
    43        prevent; I really would not like to discuss "what if", to
    44        speculate on something that will require a very intense
    45        answer.  Could you be more specific in terms of your
    46        question?
    47
    48   MR. JUSTICE BELL:  It was a hypothetical question.  It was one
    49        which, I must say, I did not understand.  Hypothetical
    50        questions are difficult in the first place.  They are even 
    51        more difficult if the person has just said:  "I do not know 
    52        of that happening."  Maybe it happened, maybe it did not, 
    53        but he does not know.  Then to ask him a hypothetical
    54        question about it is really ----
    55
    56   MR. MORRIS:  Give another example.  Australia has rainforests;
    57        yes?
    58        A.  As far as I know.  I have not seen it.
    59
    60   MR. JUSTICE BELL:  Let us pause there.  I just want to ask one

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