The fourth day began with Mr Morris again providing references to points he had not had time to find the previous day. He then progressed into a detailed summary (which would continue for the rest of the day) into the evidence relating McDonald's use of beef from the Latin American countries of Brazil and Costa Rica.
He began by refering to the evidence that had been accidentally disclosed by McDonald's which revealed that exports of beef from Brazil had been used by McDonald's in the UK in 1984. This was further backed up when Helen Steel had called the owner of the Brazilian supply plant - Lord Vestey - as a witness. He admitted he sent 5 consignments for McDonald's UK stores, and further that the beef emanated from the general market in Central Brazil from unknown sources. The defence expert Professor Susanna Hecht stated that these markets would have included significant amounts of beef cattle raised on ex-rainforest land.
Mr Morris then gave various statistics regarding the number of stores in Brazil; that there were 63 stores there in 1990, and by 1995 there were 243. He compared this to the UK to give an idea of the levels of beef supplies required by such a number of stores. In the UK, he said, there are almost 700 stores, and they require the supply of over one million beef patties every day. He said that, as McDonald's only use approx 10% of each cow, the volume of beef used had to be multiplied by a factor of ten to get the true number of cattle raised for McDonald's benefit.
Mr Morris then talked about the high quality of the witnesses called for the defence in relation to cattle ranching and beef production in regions of tropical forests. He pointed out the failure of McDonald's to seriously challenge the evidence, or the expert nature of the defence witnesses.
He compared the high quality, independent expert witnesses for the defence with the witnesses used by McDonald's. He refered to the evidence given by Mr Cesca (Director of Global Purchasing and World-wide Trade for McDonald's corporation), who he claimed, had relied almost exclusively on hearsay. He later added that the evidence had been incomplete and vague regarding the issue of companies and regions suppling McDonald's. Mr Morris latter offered as a comparision, Dr. Carriere, an expert witness for the defence, "who is a senior research associate for the Centre of Latin American Research in Amsterdam since 1974. His main research area is politics and degradation in Latin America so that is very appropriate to what we are concerned with here, looking at the relationship between the beef industry and ecology."
Another argument over the various possible definitions of the term 'rainforest' and 'tropical forest' occured. This argument is pivotal to the plantiffs' case. They have sought to apply a particularly narrow definition to the word 'rainforest' in order to make the defence's case as difficult to prove as possible. Mr Morris would later refer to evidence that right up to 1983, areas within Costa Rica that had been scientifically identified as rainforest, had been deforested and replaced by ranches supplying McDonald's local stores in Costa Rica. Althought defendants don't accept the plantiffs' limited definition of the word 'rainforest' (and it being distinct from 'tropical forest' in the public mind), it could still be shown that rainforest has been deforested for McDonald's eventual benefit.
The next issue Mr Morris explored was the evidence in the case about McDonald's role in causing environmental and social damage in Brazil. He proceeded into the issue of displacement of people by the cattle ranching industry. He quoted witnesses that had stated that cattle ranching was the most significant cause of deforestation. He reminded the court about the role of soya produced in Brazil (which the defendants have shown was used in the 1980s by cattle supplied to McDonald's in Germany) in this dispacement / deforestation process. (Soya production will be covered by the defence on Day 5 of the Closing Speech).
Mr Morris refered to the statistical inevitability that McDonald's in Brazil uses beef from rainforest regions, trucked in from such regions to be fattened up and sold on the open market in Central Brazil.
He talked about the evidence that exporters in Costa Rica and Guatamala had admitted to supplying companies in the US that supply McDonald's. He continued by saying that only an incrediably well policed system (and evidence has shown that it is not) would prevent it from being inevitable that McDonald's in the USA had used those same supplies.
Mr Morris refered to the eye witness evidence of defence expert Sue Brandford about areas identified by McDonald's as their supply sources in Goias State - she had conducted research and investigation in those very areas over 20 years and witnessed evictions of indigenous peoples, and the clearing of rainforest for cattle ranching.
The court adjourned slightly earlier for lunch at 12:50pm
Returning from lunch, Mr Morris said that he had finished with his summary of the evidence relating to Brazil and started on the issue of Costa Rica. He quoted Mr Rampton, who had said during his opening speech that in Costa Rica, the when the first McDonald's restaurant was opened in 1970, some of the land on which the beef was raised had been rainforest up to the 1960s.
There was a brief debate about whether Mr Morris could submit as evidence, an 'admission against interest' within the statements of uncalled witnesses for the plantiffs as evidence. Mr Rampton claimed that it could ' not be tendered in evidence by the other party' despite the fact it was contained in a signed statement of McDonald's UK Public Relations Officer Eddie Bensilum. But unluckily for McDonald's she had been interviewed by the journalist, David Rose of the Observer who had testified for the defence that she had told him: "I think we would admit that before that time it was rainforest. We have to accept that. All we can do is to ensure that deforestation, does not continue on our behalf."
Mr Morris then continued for some length by refering the court to a number of maps of the regions involved and the identification of various types of forest; wet, moist, dry forest etc and areas of deforestation. The defence witnesses on this subject had said that the deforestation was greater than the maps indicated because the established ranches would be expanding their development (read, clearing the forest) on land within and adjacent to their plots. He brought up evidence relating to the continually expanding world-wide demand for hamburgers, the resulting process of deforestation and it's time scales, the dispossession of people from land as cattle ranching areas expand, the incentive to clear land resulting from the use of supplies from previously established areas, and the continuing threat to the rainforest caused by the expansion of such ranches.
Mr Morris approached the end of his submissions by providing the references to the doubling of beef exports from Costa Rica (that had been referred to the previous day) and he added that while production for exports had increased, the local consumption decreased. He latter quoted McDonald's witness Donald Monroe of GISA (a major beef processor in Costa Rica) who had said, "..about seventy percent of the meat processed in our plant is intended for the production of fast food mainly as hamburgers, minced meat and similar products. About 95 percent of our output goes to the United States." He condemned McDonald's main witnesses from Brazil and Costa Rica as they were personally implicated in profiteering from the import/export industry which was directly responsible for rainforest destruction.
He concluded that there was a 'fundamental contradiction' in McDonald's involvement in Costa Rica. The point being that while McDonald's say they were using beef from farms established in the 50s, those farms would have continued deforesting their land throughout the 60s, 70s and even the into the 1980s. Yet their witnesses had tried to dodge any responsibility for this.