Day 068 - 16 Dec 94 - Page 15

     
     1        A.  That one, I do not know.  I have never looked into
     2        that.  All of the animals are identified, but I have never
     3        looked into that.
     4
     5   MR. MORRIS:   What I am saying is when McDonald's -----
     6
     7   MR. JUSTICE BELL:  Might I make a suggestion?
     8
     9   MR. MORRIS:  Yes.
    10
    11   MR. JUSTICE BELL:  If you put what you suggest is a real live
    12        situation and then ask him what there would be to identify
    13        where it had come from or was going to, and so on.
    14
    15   MR. MORRIS:  Your suppliers make the burgers, the patties; yes?
    16        A.  That is correct.
    17
    18   Q.   They receive beef, say, for example, from slaughterhouses
    19        and from warehouses; would that be correct?
    20        A.  That is correct.
    21
    22   Q.   Are they the main two sources of beef purchased by a
    23        supplier?
    24        A.  That is correct.  So far as I know, they are the only
    25        sources.
    26
    27   Q.   Warehouses and slaughterhouses?
    28        A.  We do not buy from warehouses.
    29
    30   Q.   The suppliers?
    31        A.  No, they do not buy from warehouses.  We only buy
    32        directly from slaughterhouses.
    33
    34   Q.   Slaughterhouses?
    35        A.  Or deboning facilities.
    36
    37   Q.   Right.  So, is there a specification not to buy from
    38        warehouses for some reason?
    39        A.  No.  Beef is not stored in warehouses, the beef that we
    40        use; that beef is fresh.  It only lasts -- it is our
         specification that it has to be fresh.  So, there is not --
    42        first, there is not a need for us, because we have fresh
    43        supplier every single day, our suppliers are being supplied
    44        directly by the slaughterhouses; and it is extremely
    45        expensive to store beef in warehouses to sell it later on
    46         -- the space, energy, facility cost, money tied up.  As
    47        I mentioned before, we have tremendous volumes.  One day of
    48        storage costs us an incredible amount of money, and there
    49        is no incentive, there is no need for us to do it, so we do
    50        not do it. 
    51 
    52   Q.   Again, it is a tangent:  if you export from Uruguay to 
    53        Malaysia, which is a great distance ---
    54        A.  That is correct.
    55
    56   Q.   -- there is going to be quite a substantial time difference
    57        from the slaughter ---
    58        A.  That is correct.
    59
    60   Q.   --  to production?