Day 313 - 13 Dec 96 - Page 30


     
     1        language is not admissible itself as evidence, which indeed
     2        may be the case, then the Portuguese language map from
     3        Brazil is not admissible as evidence.  It is only a guide
     4        to an expert who interprets it in the witness box, and I
     5        would say that we are not stating that documents in another
     6        language are admissible as evidence in this case, but we
     7        are saying they are capable of being interpreted by experts
     8        in the witness box who appreciate what is being said in
     9        that document or enable to interpret it to the court.  So,
    10        in fact, the Portuguese map in itself is probably under the
    11        law not admissible as evidence except as a tool for an
    12        expert in the witness box.
    13
    14        Can I just say, in terms of accuracy of figures there is a
    15        whole series of figures in the rainforest submissions on
    16        pages 25, 27 -- well, 34 and 35, and in fact table 1
    17        and...  Yes, table 1, and all the figures regarding
    18        McDonald's, which relate to McDonald's responsibility, have
    19        to be multiplied by ten in terms of head of cattle, which
    20        is something that has come up a number of times in the
    21        case, so when, for example on page 25, McDonald's say that
    22        their annual consumption of cattle in Brazil was 40,000
    23        head, the actual number of cattle that would have been
    24        needed for McDonald's use would have been 400,000, of which
    25        they would have taken ten per cent.  So when they say their
    26        total was 0.22 per cent of the annual national total it is
    27        in fact that 2.2 per cent of the cattle reared in Brazil
    28        some parts would have gone to McDonald's.  That is on
    29        page 25.
    30
    31        The same applies to page 27 with the figures given for
    32        early years.  For example, 1984, say, 3,456 head of cattle
    33        should read 34,566 head of cattle.
    34
    35        On top of page 34, when they give their brief consumption
    36        as a percentage of the world total -- no, sorry, they were
    37        saying in 1988 it was about 0.6 of the world total.  In
    38        fact, that would have meant that six per cent of cattle
    39        raised in the world some parts of it would have gone to
    40        McDonald's products.
    41
    42   MR. JUSTICE BELL: Where do you get that?
    43
    44   MR. MORRIS:  I am trying to check this, because I am relying on
    45        Mr. Rampton's figures.
    46
    47   MR. RAMPTON:  Yes, but there is a difference between consumption
    48        of head of cattle which are beasts and consumption of beef
    49        which is in weight pounds, and the figures there are weight
    50        pounds, and this seems to me to be a submission about the
    51        facts of the case and nothing to do with the law at all.
    52
    53   MR. MORRIS:  No...  Yes, all I am saying is that if it is about
    54        the amount of cattle physically needed for McDonald's then
    55        I accept it has to be ten times the amount, percentages; if
    56        it is just about the volume of actual physical raw beef,
    57        then obviously Mr. Rampton's figures are right.  I am not
    58        saying he has wrong figures.
    59
    60   MR. JUSTICE BELL:  The point is that you have made your point

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