Day 287 - 25 Oct 96 - Page 04


     
     1   MR. MORRIS:   Yes.  I think I have indicated my views that Dr.
     2        Gonzales was a very contradictory witness, obviously not
     3        independent, and we would say obviously not an expert in
     4        any relevant issue in this case because of the nature of
     5        his replies.
     6
     7        He did say on day 68, page 33, line 12: "We have never even
     8        mentioned that we were looking at moving product from
     9        Brazil into any other country".  And then, miraculously,
    10        later on in his evidence he admitted that in fact Brazilian
    11        beef had gone to McDonald's in other countries.  So I just
    12        wanted to point that out as what we would say was -- well,
    13        could be construed as an attempt to mislead the court.
    14
    15        Just while I am on the subject of Dr. Gonzales and getting
    16        him out of the way, he did say on day 67, page 53, I am not
    17        sure exactly what line:  "We have no control over what
    18        animals go into the slaughter house, we cannot go and ask
    19        every farmer in the world that can potentially supply
    20        McDonald's."  And that was about traceability.
    21
    22        His admissions about Uruguay, Argentina and Switzerland,
    23        use of beef emanating from Brazil; Uruguay were on day 68,
    24        page 53; Argentina was day 69, page 27.
    25
    26   MR. JUSTICE BELL:  Just pause a moment.  Uruguay was what?
    27
    28   MR. MORRIS:   Day 68, page 53.  Argentina was day 69, page 27.
    29        But on the subject of Argentina, I think we actually got a
    30        great deal more information from Mr. Cesca on that and I
    31        have not got the references specifically.  Switzerland was
    32        day 69, page 28, line 30.  He did say that all Brazlow's
    33        meat comes from the same area, so if they export anything,
    34        even if it is not for McDonald's, it will follow the same
    35        policy about the rainforests.  That was on day 69, page 28,
    36        line 30.  And therefore that we can assume that any
    37        destructiveness of McDonald's usage in Brazil, in the
    38        stores in Brazil, which you agree happened, would apply to
    39        any exports by Mr. Gonzales' admission.
    40
    41        Just one point; I do not know if it was....  Day 67, page
    42        59 and page 60, Dr. Gomez Gonzales stated that there was no
    43        record of any Costa Rican supplier who had supplied any
    44        other McDonald's restaurants around the world, but of
    45        course he had never investigated in the export department.
    46        I am not sure whether that was the same days that that is
    47        the reference from, the second point, but we have heard
    48        that, I have made that point, I think, anyway, already.
    49
    50        So he is coming to court and saying there has never been 
    51        any records about exporting to other McDonald's and then he 
    52        is saying he has never actually looked in their export 
    53        facility in the same complex to check.  That was day 59,
    54        line 52.  He is relying entirely on the letters that we
    55        have seen, which again are completely, we would say,
    56        ambiguous and worthless as any kind of guarantee or
    57        certification, or even, because of their ambiguity, it may
    58        be the only conclusion, deliberately evasive to avoid
    59        having to tell the truth.  He does say though, he does
    60        recognise this export capability of their supply firm in

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