Day 056 - 28 Nov 94 - Page 19

     
     1        is quite widespread?
     2        A.  Yes, but that each mill will have totally different
     3        situation and many mills will be totally satisfied from its
     4        own forest resource.
     5
     6   Q.   I understand that, but you would not have mentioned it if
     7        it was something that was insignificant, would you?
     8        A.  I have mentioned it because it would be wrong not to
     9        say that individual countries may have to import some of
    10        their raw material to satisfy their total needs.
    11
    12   Q.   There is no problem with that, is there, using imported
    13        material?
    14        A.  No, the only problem with imported material is, in
    15        fact, a plant health consideration, and this country in
    16        particular, but also other European countries, have very
    17        closely controlled monitoring programmes at the borders to
    18        ensure that diseases that might affect the forest are not
    19        imported with imported material.
    20
    MR. JUSTICE BELL:  We will take our five minute might break
    22        there.  Mr. Morris, I would like you to bear in mind that
    23        the only -- I say only -- what McDonald's complain about in
    24        this leaflet, if that is what the leaflet means, in
    25        relation to timber and forest is the suggestion, as they
    26        would have it, that McDonald's are guilty of "the
    27        destruction of rainforests, thereby causing wanton damage
    28        to the environment and (c) use and have used lethal poisons
    29        to destroy vast areas of Central American rainforests to
    30        create grazing pastures for cattle to be sent to the United
    31        States as burgers and pet foods and to provide fast-food
    32        packaging materials".
    33
    34        In your particulars of justification, I may have missed
    35        something, but the two parts which seem to relate to forest
    36        and trees are:  "According to McDonald's own literature, it
    37        takes 17 trees to produce a ton of paper, and the huge
    38        scale and nature of the First and Second Plaintiffs'
    39        business inevitably involves them in purchasing many tons
    40        of paper, most of which is not recycled and which,
         therefore, contributes to the destruction of trees and
    42        forests".
    43
    44   MR. MORRIS:  Yes.
    45
    46   MR. JUSTICE BELL:  Those are the matters which are pleaded.
    47
    48   MR. MORRIS:  Yes.  I think our position is quite clear, that the
    49        rainforests issue is a separate issue regarding cattle
    50        ranching.  So, we are talking about McDonald's paper 
    51        supplies for packaging. 
    52 
    53   MR. JUSTICE BELL:  I understand that, but that does not affect
    54        what I have just said, does it?  You are saying that it
    55        takes 17 trees to produce a ton of paper, you say,
    56        according to McDonald's own literature.  You say that the
    57        whole huge scale and nature of McDonald's business
    58        inevitably involves them in purchasing many tons of paper,
    59        most of which is not recycled and which, therefore,
    60        contributes to the destruction of trees and forests.