Day 078 - 26 Jan 95 - Page 31

     
     1   Q.   Or make assurances?
     2        A.  Not to my knowledge.  It is not a letter or a subject
     3        I know anything about.
     4
     5   Q.   It appears to be another untruth, does it not, about not
     6        using cattle reared in former rainforest areas?
     7        A.  No, I disagree with that; I just told you why.
     8
     9   MR. JUSTICE BELL:  It does not really matter what -----
    10
    11   MR. RAMPTON:  It is what your Lordship thinks that matters.
    12
    13   MR. JUSTICE BELL:  Yes, it is.  You have been pretty -----
    14
    15   MR. MORRIS:  I am trying to be careful.
    16
    17   MR. JUSTICE BELL:  I know, bear it in mind.
    18
    19   MR. MORRIS:  We have some disclosed handwritten documents from
    20        the Plaintiffs which were mistakenly disclosed to the
         Defence.
    22
    23   MR. RAMPTON:  What Mr. Morris is referring to is the privileged
    24        drafts which is a privilege I earlier waived done by the
    25        partner in Barlow Lyde and Gilbert whose name appears under
    26        that typewritten letter which we have just looked at.  If
    27        there is a question, a fact, which Mr. Walker can usefully
    28        answer in relation to those draft letters, by all means let
    29        it be put.  But I do object to Mr. Morris using a purported
    30        cross-examination simply as an opportunity to read things
    31        out in open court.
    32
    33   MR. MORRIS:  Not really because these are -----
    34
    35   MR. JUSTICE BELL:  Let us have a look at the documents and then
    36        hear what your question is.  Where do I find them?
    37
    38   MR. MORRIS:  I am not sure because the Plaintiffs, of course,
    39        removed them from the file.  I am not sure if they got back
    40        or where they are.  It is volume XVI, it is tab 9 and it is
         page 86 of that tab, I think.
    42
    43   MR. JUSTICE BELL:  Is it one page of longhand with a "45" in the
    44        middle at the bottom?
    45
    46   MR. MORRIS:  The problem is that there are actually six pages of
    47        handwritten notes originally disclosed.  They have not all
    48        been put back in.  One of the pages actually refers to
    49        Mr. Walker.  It is not that page.  This is the page which
    50        McDonald's mistakenly revealed to us that they had, in 
    51        fact, imported Brazilian beef. 
    52 
    53   MR. JUSTICE BELL:  Let me just read this page.
    54
    55   MR. MORRIS:  I do not know if the Plaintiffs have a copy of the
    56        rest -----
    57
    58   MR. JUSTICE BELL:  Just pause and let me read it.  What do you
    59        want to do?  Do you have a clean copy?
    60