Document 0gD8dmyxD60xGE3ZJNmvZ7wKn

Marcella Duncan 7-22-04.txt 21 OF THIS DEPOSITION. 22 MR. FISHBACK: ALL RIGHT. 23 Q. WITH RESPECT TO THIS -- 24 MR. CORCORAN: I'M SORRY. BEFORE SHE 25 ANSWERS -- 0043 1 MR. PARKER: SHE'S NOT GOING TO ANSWER, STEVE. 2 MR. CORCORAN: -- I HAVE AN OBJECTION TO MAKE TO 3 THAT QUESTION. 4 VAGUE AND AMBIGUOUS, OVERBROAD, CALLS FOR 5 SPECULATION, AND ALSO ASSUMES FACTS. 6 MR. FISHBACK: ARE YOU INSTRUCTING HER NOT TO 7 ANSWER? 8 MR. PARKER: YEAH, SHE'S NOT GOING TO ANSWER 9 THAT QUESTION UNLESS IT HAS SOMETHING TO DO WITH VICTOR 10 GASKETS. WE'VE HAD THREE HEARINGS ON THIS TOPIC BEFORE 11 COMMISSIONER HEWITT. 12 MR. FISHBACK: ARE YOU INSTRUCTING HER NOT TO 13 ANSWER? 14 MR. PARKER: YES. NEXT QUESTION. 15 BY MR. FISHBACK: 16 Q. DO YOU RECALL DURING THAT TIME THAT THERE WAS, 17 IN ADDITION TO F.S. 1178, OTHER -- STRIKE THAT. 18 DO YOU RECALL OTHER POPULAR GASKET PARTS THAT 19 WERE BEING SUPPLIED TO GENERAL MOTORS IN A SUBSTANTIAL OR 20 SIGNIFICANT AMOUNT DURING THAT TIME PERIOD OF 1968 TO 21 1970? 22 MR. PARKER: OBJECTION; VAGUE AND AMBIGUOUS, 23 OVERBROAD, CALLS FOR SPECULATION. YOUR USE OF THE WORD 24 "SUBSTANTIAL" AND "POPULAR" ARE GOING TO BE -- 25 MR. CORCORAN: STEVE CORCORAN. I'LL JOIN IN 0044 1 THE OBJECTIONS. 2 MR. PARKER: YEAH, l'M NOT GOING TO TELL YOU 3 HOW TO ASK THE QUESTION. NEXT QUESTION. 4 GO AHEAD, PLEASE. 5 BY MR. FISHBACK: 6 Q. DO YOU UNDERSTAND THE QUESTION? 7 A. YES. 8 Q. GO AHEAD. YOU CAN ANSWER. 9 MR. PARKER: TO THE EXTENT THAT YOU UNDERSTAND 10 IT. 11 THE WITNESS: THE FACILITY THAT I WORKED AT IN 12 1968, 1970 DID NOT SELL TO GENERAL MOTORS. 13 BY MR. FISHBACK: 14 Q. THE F.S. 1178 YOU SAID WAS A SMALL BLOCK CHEVY? 15 A. FOR AFTERMARKET SALES. 16 Q. OKAY. WHEN YOU SAY AFTERMARKET, WHAT DO YOU 17 MEAN BY THAT? 18 A. WE SOLD TO AUTOMOTIVE PARTS DISTRIBUTORS WHO 19 WOULD SELL TO, EVENTUALLY, AN END USER WHO WAS FIXING HIS 20 CAR IN THE BACKYARD. 21 Q. SO THE FACILITY THAT YOU WERE WORKING AT IN 22 CHURUBUSCO, INDIANA, THAT WAS THE DISTRIBUTION FACILITY 23 THAT'S GOING TO -- DESIGNED TO FACILITATE THE SUPPLY OF 24 PRODUCTS TO YOUR LOCAL AUTOMOTIVE SUPPLY STORE? 25 A. CORRECT. 0045 1 Q. IN THAT REGARD, WERE THERE GASKETS OR GASKET 2 KITS MANUFACTURED BY DANA CORPORATION OR SUPPLIED BY DANA 3 CORPORATION THAT YOU RECALL BEING POPULAR FOR USE ON 4 GENERAL MOTORS VEHICLES? 5 A. I -Page 19