Day 237 - 18 04 96 - Page 56

     1   MR. RAMPTON:   Thank you, Mr. Carroll.
     2
     3                        (The witness withdrew)
     4
     5   MR. MORRIS:   There is a further -- a supplementary statement of
     6        Charles Secret from Friends of the Earth regarding the
     7        rainforest, tropical forest, issue which I only just got
     8        this afternoon in Court; I gave it to the Plaintiffs.
     9        (Same handed).  If I can say that it is quite hard work for
    10        me to get some of that.  It requires a bit of thought
    11        rather than a quick scan but, as far as I know, it was
    12        intended to be slightly longer and I do not know if,
    13        through the fax, there is some problem with it getting -- a
    14        complete statement getting through.  So if there is a----
    15
    16   MR. JUSTICE BELL:   Are you confident that it is supposed to end
    17        at 4.4?
    18
    19   MR. MORRIS:   He has not signed it and I think it might be
    20        longer.  So what I will do I will check and, hopefully, by
    21        tomorrow I will get it faxed to the Plaintiffs if there are
    22        any additional paragraphs.
    23
    24   MR. JUSTICE BELL:  Right.  Is there anything more we should do
    25        now?  Otherwise, I will adjourn until ----
    26
    27   MR. RAMPTON:   My Lord, I would be very grateful if your
    28        Lordship would.  The reason I say that is this.  I think it
    29        was yesterday I was handed a supplementary statement by
    30        Fiona Watson well past the proper deadline, which is five
    31        working days before she is due to give evidence.  In
    32        consequence of that, I can see that we have got a
    33        considerable amount of geographical research to do.
    34        Whether that is going to be simple or difficult, I do not
    35        know yet because I have not started.  If it should turn out
    36        that I am not ready for Miss Watson on Monday morning, I
    37        shall notify the Defendants.
    38
    39        The reason I say that is that she has now given precise
    40        locations within Matto Grosso do Sul where she says Indians
    41        have been uprooted by a cattle farmer.  She has not always
    42        given a date, but she has given the places.  My existing
    43        maps of Brazil do not give the names of those places.  I,
    44        therefore, have to acquire a map of Brazil since she did
    45        not serve one with her statement.  What I am hoping for is
    46        a map of the province, a large scale map of the state or
    47        province of Matto Grosso do Sul so I can see exactly where
    48        these places are.  But, at the moment, I have a bit of a
    49        problem.
    50 
    51   MR. JUSTICE BELL:   What I would suggest is, in effect, I think 
    52        what I have suggested with witnesses before, that Miss 
    53        Watson should in any event be called, I would suggest.
    54
    55   MR. RAMPTON:   Yes.
    56
    57   MR. JUSTICE BELL:   That, having given her evidence in-chief,
    58        you cross examine her.  If, in the light of material in her
    59        additional statement or extra material which is given in
    60        oral evidence on Monday, you think you have to make further
 
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