Day 139 - 21 Jun 95 - Page 27

     
     1        is inaccurate as it is strictly written?
     2        A.  Are we talking about the specific things coming
     3        from -----
     4
     5   Q.   All we are talking about at the moment is pages 1394 and
     6        1395.
     7        A.  OK.  What I object to, my Lord -----
     8
     9   Q.   No, that is not the question I asked you, Mr. Stein.
    10        I have got the point that you say that, in effect, if one
    11        just had a quick glance at that it might be misleading.
    12        But what I am asking you to say is, is there anything in
    13        the strict wording of those two pages which you say is
    14        inaccurate, in fact?  I only ask that because Mr. Rampton
    15        does not accept that it is accurate.
    16        A.  I cannot tell you that each and every item here is
    17        accurate.
    18
    19   Q.   No.
    20        A.  I cannot do that, sir.
    21
    22   MR. MORRIS:  But when you checked the situation out, you were
    23        not alleging that they were actually quoting inaccurate
    24        USDA reports?
    25        A.  In the context in which they were articulating it, it
    26        was totally inaccurate.
    27
    28   Q.   But apart from the context, the facts of the specific
    29        pre-operation quotation from USDA, you have no doubt, you
    30        have no reason to doubt the accuracy of those particular
    31        things?
    32        A.  I did not look at those things in great detail, because
    33        as soon as I became aware that they were talking about
    34        things that had nothing to do with operations, I was
    35        concerned with whether or not there was anything that could
    36        do some potential harm or concern for our product; and as
    37        soon as I became aware that what they were citing had
    38        nothing to do, or no implication to our product at all,
    39        frankly, it was not material to me.
    40
    MR. JUSTICE BELL:  There are 40 altogether, in six plants, and
    42        the dates -----
    43        A.  Six plants, my Lord?
    44
    45   Q.   Yes, six separate plants.
    46        A.  Because we are only talking about one plant, my Lord.
    47
    48   Q.   No.  I am talking about the document.
    49        A.  I am sorry.
    50 
    51   Q.   In this document, there are six separate plants covered. 
    52        There are 40 instances which are set out.  The dates range 
    53        over the second six months of 1982.
    54        A.  You are right.
    55
    56   Q.   And they cover items such as maggots found in places, down
    57        to an instance where a dead fly was found on a table in a
    58        giblets packing area.  That is the summary of it, really.
    59        A.  My Lord, if I might, the Chicken McNuggetts were only
    60        made at the Nashville Arkansas plant.  These other plants