Document 3VVmzGGmLNQveG18xBzmMGQ0

SEP. 13.2004-2:57PM RWDM LAW FIRM TM Multi-Page NO. 653 P. 3 jkppeAraacca: Par c&e DoFendaac facooo-Xbexi sum JkftBOtr S.t.P. - Ishwrw*oV*o*,v troeavc*RoUcxvaiooo* exi )*. sdkwjjd p. Aaaor Far cbe Defendant flendlne Piru Cotipt&ys xim/ wemmr wm t flEtna 60 W*9hlA?voa Bond Stilee 900 fictrtxurafe, PefififplvaoU 15299 W: KU WU R. Wt*X RMKOimr< WZXXXBr OXCKBf MOORS* t.L.C. 9200 Hard Poskvay Std.be 210 KLA6A3 dev HlMottrl <U1% BY: IA. CUY70V B. PICKS* 1< CXNttAS K&LXM4 MiXN SM5B u BxaBdftAcioa by tee. Abboc........T, ............... a xs gMgd&atlw by Kc. CXwni.*.............. .... .............. 19 OEioemo* exbxbxt no. (VOTE) fixanm kq a 1 cd 1966 wlmI went to GcoomIndustries in 2 Stcpbcnvffle, Texas, and -wem to wodc. It was a 3 wholly-owned subsidiary of Gap or Genuine ' 4 Automotive Parts, and fiom.toeml waitto 5 Motganfidd in 1974. and I'mftae until today. 6 Q. Okay, when you went to Morganfield in '74, were you 7 wedting for Raytoc? 8 A_Ko. it was stinGeaam Industries. 9 Q.Okay, and wben did yonr employer change from Genai 10 Industries? 11 A. 1984. 12 Q.Who did you go to wade for in '847 13 A-Rayloc. 14 Q.Yafu've worked for Rnyloc ever since7 15 A. Yes. Id Q.Olcay. Can you explain kt't go 8ack to Genartn 17 ' Industries in 1966. Can yon explain das 18 xtdationsbip,,ifany, to KAMI 19 A.lbey^pli^.dioN^Astt3nttomtoca 20 ttawefroig iamt of toe Wife 21 the exception of Oklahoma City and to^ also had a 22 branch Tulsa, and toey also had toe Standard 23 Ut^juwisupiaCSncaeo.NoiajalaadSaQkViDasel 24 toinlc h was a part of " it -was not part of OAP, ' 25 bm we had toe rest of it toroosb toe central all Page 3 1 CHARLES WILLIAM ALLEN, 1 toe way out into Des Moines and Dewitt and Kansas 2 of lawful age, after having been first duly sworn 2 City. 3 to tell fee truth, the whole truth, and nothing but 3 Q.SOi for a certain section of toe country, Gcnaut 4 the truth, testified as follows: 4 was a supplier for NAPA7 5 . EXAMINATION . 5 A. Yes. 6 BY MIL GIANARIS: 6 7 Q. Sir, please state your name. 7 8 A. Charles William Alien. 8 9 Q.Charles WSUiam AQop? .. 9 A.Yes. 10 A.Yes, A-L-L-E-N. 10 Q.What was your job -- go through your job starting 11 Q.Where do you live, Mr. Allen? 11 in *66 to toe present. 12 A.I live in Morganfield, Kentucky. 12 A.I was a foreman in toe plant 13 Q.Cam you give us your, address, please? 13 Q.Olcay. 14 a.206 Valley Drive. 14 A.And I moved hum that to a plant manager, and, 15 Q.What'S your -date of birth? 15 then, when I went to Morganfield, I was the plant 16 A. 9*17-39. . 16 manager toere, then, in ' 84 when the buyout came, I 17 Q.Olcay, are you a married man? 1? went to general manager. 18 A. Yes. 18 Q. Okay. And you're sttH general manager? 19 Q.Where do you work? 19 AYes. 20 A.I work for Raylocin Morganfield, Kentucky. 20 Q.ft's niy understanding that Genaut had, for lack o 21 Q.Can you just -- let's rewind and go back to when 21 a better tenn and maybe it's the proper term, 22 you got out of bdgh school, let's say. Give me 22 competitors or a conple of competitors toronghoo 23 your wodc history, if you would. 23 toe country who also supplied NAPA, is tost 24 All went to-work at Metro Electric Company in 24 correct? 25 approximately 1959. I worked there until mid year 25 A Well, Genuine Parts would be one. JOHN M. BOWEN & ASSOCIATES - (816) 421-2876 Page2-P