Day 158 - 19 Jul 95 - Page 33


     
     1        I think -- sorry, I cannot remember -- large landowners, he
     2        earlier on says that that is basically cattle ranchers.
     3
     4        So, although I have dealt with it all in one go, that
     5        actually covers quite a bit of the pleading; not just as a
     6        question of reasonable belief but, in fact, as to come,
     7        evidence from our own witness.
     8
     9        There was only one thing I wanted to move on to after
    10        that.  I think that covers -- yes.  Just in case that point
    11        was missed, in the pleading, in the middle of the first
    12        paragraph of that pleading, paragraph 1, it talks about
    13        Mato Grosso, which I have dealt with, and Goias, which
    14        I only briefly covered, but I did quote from Hoofprints on
    15        the Forest, how Goias, the rate of deforestation was
    16        rising.  If you remember, it was on, I think, page 112.  It
    17        was 193 per cent between 1975 and 1978, the rate of
    18        deforestation.  Of course, exactly what that means,
    19        Mr. Shane will deal with if he comes, or we can ask him for
    20        further details -- but the point being that both
    21        Mato Grosso and Goias are regions which include and/or
    22        border areas of ex-rainforest land, which is in the
    23        proposed pleading.
    24
    25        The next line -----
    26
    27   MR. JUSTICE BELL:  Just pause a moment.  I just want to look at
    28        how you start your pleading on the destruction of the
    29        environment again.
    30
    31   MR. MORRIS:  I had not actually read that.
    32
    33   MR. JUSTICE BELL:  I think you should.
    34
    35   MR. MORRIS:  It says "tropical forests, commonly known as
    36        rain forest".  So that has been ----
    37
    38   MR. JUSTICE BELL:  You have already referred in the second
    39        paragraph, as it appears in the abstract 2, you said you
    40        rely upon the findings of Mr. Shane published under the
    41        title of "Hoofprints on the Forest".
    42
    43   MR. MORRIS:  Yes.  In the very first paragraph, it says -----
    44
    45   MR. JUSTICE BELL:  Yes.  I have read that again, as well.
    46
    47   MR. MORRIS:  So, really, this pleading is not so much a new
    48        pleading, as a particular relating to an already pleaded
    49        matter.
    50 
    51        If I can just deal with the sentence in the pleading, in 
    52        the amended pleading, which starts, "A company 
    53        representative":
    54
    55        "A company representative has stated that it would have
    56        been acceptable to use beef reared on rain forest land
    57        cleared before the first store opened in a country."
    58
    59        This is referring to Dr. Gomez Gonzales.  I will just get
    60        the transcript.  It was day 68; it was on 16th December --

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