Day 002 - 29 Jun 94 - Page 24


     
     1        McDonald's which they say they do, to find out if they
              conform to this so-called "no imports policy" or "no ex
     2         rainforest land policy", or whatever.
 
     3        By the way, I should say that they have now admitted, as
              Mr. Rampton said yesterday, when they started in 1970 they
     4        were using beef reared on land as deforested within the
              previous ten years, which contradicts their public
     5        statements and legal letters they sent to solicitors.  But
              the point is they have lied about that which is one of the
     6        fundamental planks of their policy.  The other plank of
              their policy is that they do not use imported beef in the
     7        States.  So, if they have lied about one thing, it is
              quite reasonable for us to try to identify the documents
     8        that could go towards the truth of the "no imported beef"
              policy.
     9
              I am not just saying this to sound biased.  I am saying
    10        this to the court, to yourself especially, now because of
              the counterclaim where McDonald's have said the criticisms
    11        are lies.  They are under an obligation to prove that they
              are untrue, these claims.  Therefore, the detail, I will
    12        not go into it because it is not worth it, but the
              detailed application we made for discovery, where we have
    13        named documents, we have asked for minutes of corporate
              meetings, we have asked for a full set of correspondence
    14        rather than individual letters we have which were
              unsatisfactory, which we disclosed, and the total
    15        disclosure relevant to Coope Montecillos that have been
              supplying McDonald's in Costa Rica since 1970, including
    16        beef raised on ex rainforest land, is six pages.
 
    17        They say they do not have any other documents relating to
              the source, whether it comes from ex rainforest land or
    18        whether they had correspondence with McDonald's
              Corporation in the States about importation.  So the point
    19        I am making is six pages covering something that is at the
              centre of one of the main points of the case which is the
    20        destruction of the environment and the Coope Montecillos
              meat factory is what we say is a cover up.
    21
              We are calling evidence from David Rose of admissions to
    22        him by McDonald's about the use of ex rainforest land for
              their beef supplies.  We will be calling experts in this
    23        case to talk about the destruction of the rainforest and
              the beef industry.  Our witness on the publication of this
    24        leaflet which I mentioned before which is virtually
              identical to the London Greenpeace leaflet -- that is
    25        Patrick over there doing the video.  He is our witness.
              He has kindly come to help for a couple of weeks in the 
    26        case as a volunteer. 
  
    27        He was sent a letter by McDonald's Corporation instructing
              him to apologise and pulp this leaflet because they
    28        claimed in that letter that McDonald's had never used any
              beef reared on any ex rainforest land.  Mr. Rampton
    29        yesterday admitted that that was not the case.  So
              Mr. Smith is going to be an important witness.
    30
              Just to say something else about discovery:  We have

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