Day 092 - 27 Feb 95 - Page 34


     
     1   Q.   So Cargill buy from lots of different places, do they?
     2        A.  They are big in laying hens.  I believe they are the
     3        biggest in the US and they have their own farms.  They do
     4        not really buy from places they own.  They produce them.
     5
     6   Q.   When Mr. Rampton was asking you questions, you said it was
     7        typically four to a cage.  In the units that you were
     8        referring to then, how many, what would be the size of
     9        those units?
    10        A.  The same.
    11
    12   Q.   The same size cage?
    13        A.  Yes.
    14
    15   Q.   Then the same size shed?
    16        A.  Yes.
    17
    18   Q.   Then the cages would be stacked several high?
    19        A.  They will be stacked, but it is not one on top of the
    20        other.  It could be one here and then another behind them.
    21          So, they are not one on top of the other.  It is
    22        collated.
    23
    24   Q.   Why are they stacked?
    25        A.  Because when they -- to prevent the droppings from
    26        falling into the other cages.
    27
    28   Q.   But why are they stacked more than one level high?   It is
    29        to get more chickens in the shed, is it not?
    30        A.  Yes.
    31
    32   Q.   How many cages higher do they go, usually?
    33        A.  Usually two, three max.
    34
    35   Q.   It is more like four or five, is it not?
    36        A.  It depends.  What we have -- you are talking the
    37        industry and then all of a sudden you go to England and
    38        then you go into the US.  Our suppliers, only two or
    39        three.
    40
    41   Q.   There will be tens of thousands of birds in each shed, will
    42        there not?
    43        A.  Tens of thousands -- no, that is too many.
    44
    45   Q.   Too many.
    46        A.  Could be thousands, yes.
    47
    48   Q.   Just 1,000?
    49        A.  It could be -----
    50 
    51   MR. JUSTICE BELL:  Could be thousands as opposed to tens of 
    52        thousands? 
    53        A.  Yes.
    54
    55   MS. STEEL:  So up to how many are you saying, 9,000?
    56        A.  No, that is probably too much.  4 or 5,000.
    57
    58   Q.   How many people are responsible for looking after each
    59        individual shed?
    60        A.  Usually, one or two.

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