Document 06bmMq1kam7BDJ8KGX57G1b5M

SEP. 13.2004 2:59PM RWDM LAW FIRM Multi-PageTM NO. 653 P. 7 Page 18 1 on some water pumps. 1 Industries, were you involved in die purchasing at 2 Q.You mentioned distribution centers. What 2 all? 3 distribution -- what locations do yon. remember 3 A-Purchasing? 4 these distribution centers; do you remember where 4 Q.Yes. 5 they were located throughout the country? 5 ANo, not at that time. 6 A-Fot Gap? 5 Q.And what year did yon get involved with the 7 Q.Well, the NAtA, you mentioned KAPAdistribution 7 purchasing of product? 8. centers or the distribution centers that had the 8 A.Somewhere around '69, maybe '68, '69, some 9 products. . 9 purchasing. 10 MR. RILEY:. Over whet time feme? 10 Q.Olmy. "What sort of purchasing were you involved 11 Q.(BY MR. ABBOT) Let's go from 1966 when you started 11 then? 12 to 1980. 12 A. Once the plant manager took over as general manager 13 A. All right, GAP supplied approximately 14 to 17. 13 of the two plants, I would help out sometime if we 14 Q.14 to 17 distribution centers? 14 were - say someone was off on vacation or out tick 15 A. Yes. 15 or something, I would help out on purchasing. I 15 Q.Who owned those distribution centers? - 16 talked with some of die people, I ordered same 17 A.Pait of them were owned by Genuine Automotive Parts 17 brake lining. 18 and some of were owned by I think the Boltons owned 18 Q.You ordered all different type ofprodnets, isn't 19 Dos Moines and Dewitt I guess the rest of them 19 that correct? 20 were gap. Only those two were probably Bolton. 20 A. Ordered American Brekebloc. 21 Q. Could you, just based oh your recollection, today 21 Q.No, I'm just talking, beyond that, all sorts of 22 let me know, identify for me, where those 22 products from American Hraktfbloc? 23 distribution centers were located? 23 ASure. I was not a purchasing person. I just 24 A. Dallas, Houston, San Antonio, Kansas City, St 24 filled in. 25 Louis, Mount Vernon, Milwaukee, Stevens Point, 25 MB. ABBOT. That's all the questions I Page 19 1 Indianapolis, Grand Rapids, Detroit, Fort Wayne, 1 have, thank you. P* 2 Louisville, Knoxville, and Nashville. I left out 2 MR. DICKEY: I don't have any questions. 3 two, Des Moines and Dewitt. 3 Do you have anything, Pat? 4 mb, DICKEY; You didn't mean Mount Vernon, 4 EXAMINATION 5 Virginia, did you? 5 BYWR.RILBY.- 6 THE WITNESS: No. 6 Q.I just want to clarify one point. Before the late 7 Q. (BY MX. ABBOT) Of dm distribution centers you 7 1980`s, if somebody went into a NAVA store and % 8 mentioned, were there any distribution centers - 8 a box of either brake Hirings or brake shoes or 9 you're aware of that are on the east coast? These 9 disk brakes dntt had the NAPA logo on the box, 10 all seem to he in the middle of the United States. 10 whose friction product would be inside that box? 11 A. Central United States. None op the east coast. 11 ATony understanding, it would be Abes. 12 Q.Nose on die east coast? . . 12 Q. Okay. 13 ANo. 13 EXAMINATION 14 Q.Whal about the west coast? 14 BY MIL ABBOT; 15 ANo, sir. 15 Q.And the basis of your understanding even at that 16 Q.And, the follow-up on that, you would have no 16 laic tnneinthe late 1980`s -- 17 knowledge of the distribution centers in the east 17 MR.KILEY; I said before the late 1980's. 18 coast or who they were buying products from, what 18 Q.(BY mb. ABBOT), I'm sorry, inUmt time frame tha 19 they were supplying NAPA stores with on the east or . 19 Mr: Eilcy was referencing, die basis of your 20 west coast? . 2fr knowledge for that statement is what? 21 Ah was always my knowledge what I was told, if they 2) A Sometimes I went to these DC's and I could see the 22 wcreHAPAdmy were buying American Brekebloc. 22' product 23 Q. Give me one second. Let me check my notes far a 23 Q.Did you ever see -- 24 second. 24 Ah had American Brekebloc on the labels. Our 13, 25 In 1966 when you started with Genaut 25 our RS. AB'sall those back in that period of time JOHN M. BOWEN & ASSOCIATES - (816) 421-2876 Page 18 - Pi