Document 15D6OeZXN1oGerNkkogJpLxqZ

THOMAS DICKSON Page 42 Page 44 1 A. Yes. 2 Q. Have you reviewed any documents prior to 3 today's deposition? 4 A Yes, some. 5 Q. What did you look at? 6 A. I looked at a letter to Ford Motor Company. 7 Q. Do you have that with you? 8 A. Yes. 9 Q. What is the date of that letter? 10 A. June 30,1983. 11 Q. And what is the substance of the 12 correspondence? 13 A It basically confirms that we were - plan on 14 using nonasbestos facings in our reman clutches. 15 MR. SMITH-GEORGE: Okay. Can we have that 16 marked as the first exhibit? 17 (EXHIBIT NO. 1 MARKED.) 18 Q. Have you brought any other documents with 19 you? 20 A Yes. I have four other documents. 21 Q. Okay. Let's go through them serially. 22 What's the next one? 23 A I have one to Sperry New Holland. 24 Q. What's the date of it? 25 A. April 28, 1986. 1 '84 was when we had made the complete change to the 2 nonasbestos. 3 Q. When was the decision to make the change? 4 When did that occur? 5 A Well, as I said before -.- and I have 6 another -- what would be an announcement to the field 7 that we were offering nonasbestos materials in 1981, 8 August 13 of 1981. 9 Q. So between August of '81 and January of '84, 10 during the process of convincing your customers to buy 11 the fiberglass clutch, you were selling the remainder 12 of your asbestos clutches? 13 MR. RADCLIFFE: Object to the form. 14 Q. Would that be accurate? 15 A That's correct. I have -- also have with me 16 an internal memo to the sales manager that states we 17 were in the process of superseding all asbestos driven 18 disc assemblies to the nonasbestos, and that was dated 19 11/4/83. 20 MR. SMITH-GEORGE: Why don't we mark the 21 '86 document as Exhibit 2. 22 (EXHIBIT NO. 2 MARKED.) 23 Q. And as Exhibit Number 3 -- what's the next 24 document you had? 25 A I had the press release of August 13,1981 -- j 1 Page 43 Page 45 1 Q. And what is the substance of the document? MR. SMITH-GEORGE: All right. We'll mark j 1 2 A Basically confirms that we were totally 2 that as 3. j 3 asbestos free January 1,1984. 3 A -- stating it was available. 4 Q. What did /all do with -- let me ask it this 4 (EXHIBIT NO. 3 MARKED.) 5 way: How would you order the component parts to the 5 A. And I had the memo to the sales manager. j 6 manual clutches? In other words, when you -- if you 6 MR. RADCLIFFE: Hold on. Are you caught 7 had to get the asbestos discs for the driven discs 7 up? 8 from either HK Porter or Raybestos, would you order 8 THE REPORTER: Thank you. 9 them in bulk or would you do it as the clutches were 9 MR. RADCLIFFE: Okay. Go ahead. 10 being manufactured? 10 MR SMITH-GEORGE: We'll mark the memo to 11 A I'm assuming you're talking about the clutch 11 the sales manager as Exhibit 4. 12 division now. 12 MS. HALES: What's the date on that? 13 Q. Correct. 13 THE WITNESS: Eighty-three. 11/4/83. j 14 A The clutch division had standing orders with 14 (EXHIBIT NO. 4 MARKED.) 15 Raybestos and H.K. Porter for hundreds of clutch 15 Q. Did you bring any other documents with you? j 16 facings to be shipped a month. 16 A One more. ] 17 Q. And at the time that you went asbestos free, 18 did you have any inventory of material that was sent 17 Q. Okay. 18 A. It's a memo to -- or it's a letter to one of j 1 19 by H.K. Porter and Raybestos? 19 our field customers, Consolidated Freightways, stating j 20 A. Yes. 20 that we were switching all our current facing J 21 Q. What did you do with that inventory? 22 A. We used it. 23 Q. After January 1 of 1984? 21 materials from asbestos to a nonasbestos material. 22 Q. And what's the date of that? 23 A July 6,1983. I f 1 24 MR. RADCLIFFE: Object to the form. 24 MR SMITH-GEORGE: Okay. We'll mark that .25 A. No, not to my knowledge. January 1,1981 -- 25 as Exhibit 5. I Henjum Goucher Reporting Services 1-888-656-DEPO 12 (Pages 42 to 45)