Day 068 - 16 Dec 94 - Page 08

     
     1        A.  For us, it is not.  Our claims that we have made
     2        throughout the years refer only to the US, the Continental
     3        US.
     4
     5   Q.   But I am just saying that in terms of official, if you
     6        like, constitution of the US DA area of authority, Puerto
     7        Rico is part of the territorial boundary of the USA?
     8        A.  I am not qualified to say that.  I do not know all the
     9        constitutional regulations.  I do not know.
    10
    11   Q.   It is in one of the documents we had, anyway.  So how long
    12        have been these zones been operating?
    13        A.  It will depend on each zone.  I do not know the
    14        specifics of each zone.  It depends when they were formed,
    15        when that was started, when they got started.
    16
    17   Q.   Before your time, was it?
    18        A.  Yes, absolutely.
    19
    20   Q.   It can be checked by the Plaintiffs, but in the US DA Meat
         Inspection Code of the laws of the United States of
    22        America, Food and Drugs, on page 5, it says that when they
    23        refer to the term "state" in the document, it means any
    24        state of the United States and the Commonwealth of
    25        Puerto Rico.  Would you accept that, that for the purposes
    26        of the US DA Food and Drug -----
    27        A.  May I have the privilege of seeing the document?
    28
    29   MR. MORRIS:   Yes, indeed.  It is actually in the documents.
    30
    31   MR. JUSTICE BELL:  Can you say where?
    32
    33   MS. STEEL:  I do not think the Plaintiffs actually put it in the
    34        trial bundles.
    35
    36   MR. JUSTICE BELL:  Let us have a look at it now.  How many
    37        copies do you have?  Is there just one copy?
    38
    39   MS. STEEL:  I have only one copy; and that is not the whole of
    40        the document either, but that is the relevant part.
    41
    42   MR. MORRIS:  The whole document was in court yesterday.
    43
    44   MR. JUSTICE BELL:  Do not worry at the moment.  I just want to
    45        understand it.
    46
    47   THE WITNESS:  What page?
    48
    49   MR. MORRIS:  It is the one with the cross on the right-hand
    50        side.  There is a specific reference there. 
    51 
    52   MR. RAMPTON:  I have to say that it does make life extremely 
    53        difficult if litigation is conducted in this way.  I do not
    54        have a copy.
    55
    56   MR. MORRIS:  Over there, on your table, there is a copy.
    57
    58   MR. JUSTICE BELL:  Let us just see where we go.  You are quite
    59        right to take the point.
    60