Document 4JpqGB32b52V40Jj2L7vnywBx

Hicks, et al. v. ACandS, Inc., et al. '' 6/1/01. Paul L. LeCour Page 166 Page 168 1 Q. All righi. Were all of the B's brake shoes? 2 A. Yts. 3 Q. Can a B also be a brake pad, disc brake pad? 4 A.' No. 5 Q. What does RS stand for? 6 Al Riveted. 7 Q. Were all of the RS brake shoes? 8 A. Yes. 9 Q. Were all or the RS between I960 and 1980 10 asbestos-containing? u' A. Yes. 12 Q. And the M, metallic, no asbestos? 13 A. Correct. Yes. . 14 Q. When was the M introduced? 15 . A. The (VI was there when { started with the 16 company in'71. It was a limited part numbers. It was 17 . primarily used for race cars, emergency vehicles. It 18 had lb own set of circumstances, as Tar as its 19 performance. The normal person would not want to put 20 it on their car. 21 Q. The disc brake pads, what do they correspond 22 to? 23 A. S would be either an asbestos or an MAO, 24 non-asbestos. We have to go with the time frame. 25. Q. When was 5 introduced?. I A. That corresponds to asbestos. 2 Q. Was that true 1960 to 1980, all AS were 3 asbestos-containing? 4 A. Yes. 5 Q. What do the A and the S stand for? 6 A. 1 don't know. 7 Q. Okay. What other disc brake pads are there? 8 A. MAS* 9 Q. And what docs that signify? .10 A. Semi-metallic. II Q. When were they introduced? 12 A. Again, in the '70s. 13 Q. What docs the E docs that have any 14 what does (hut correspond to? '15 A. e? 16 Q. Yes. 17 A. We're not there yet.. 18 Q. Okay. 19 A. We have ES. 20 Q. ES. Okay? 21 - A. Okay. ES is asbestos. 22 Q. And that would be true between '60 and '80? 23 A. Yes. 24 Q. What does the ES stand for? 25 A. Let nte go back. We might not have had ES back Page 167 Page 169 1 A. S was there when I started in'71. 2 Q. And so in 71, wer^they all 3 asbestos-containing, S's? .4 A. S's? Yes. 5 Q. At what point In time was there a non-asbestos 6 option on the S? 7 A. We'd go with MS, and it wasn't an option. If' 8 OEM came out with a semi-metallic puck pad, we plugged 9 in MS. And you wouldn't have an 5, It would only be 10 available in MS. II Q. So any time there's an S, that's an 12 asbestos-containing produevas opposed to an MS? 13 A. What time frame? . 14 Q. I960 to 1980. .15 A. Yes. 16 Q. All right. And MS is what, semi-metallic? ' 17 A. Yes. 18 Q. When was the semi-metallic first introduced? 19 . A. In the "70s. 20 Q. Are there any other disc brake pads, other , 21 than S and MS? 22. A. Yes. 23 Q. What are they? 24 A. There's ES - no - there's AS. 25 Q. What docs that correspond to? 1 in (he '60s. But you gave me the time frame from the 2 '60s through '80s. But it's still in that area. It's 3' ES. 4 Q. When was the ES introduced? 5 A. That had to be in the '70s, late '70s. 6 Q. And what docs the ES stand for? 7. ' A. 1 don't know.. 8 Then we had an MES that was semi-metallic 9 for that line. 10 Q. Okay. Any others that were out there? 11 A. Any others what? 12 Q. Any other disc brake pads? 13 A. During what time frame? 14 Q. .'60 lo 'SO. 15 A. No. . 16 Q. I'm a liule confused. The AB, I think you 17 .indicated, was American Brakeblok? IS A. Yes. 19 Q. Why is there a specific manufacturer 20 designation on one and not on the others? 21 A. Well, because that was AB Stopper; and that's 22- why they called it Stopper. That was the flagship at 23 one time, hefore we came out with the B and the RS, 24 the premium. So it just stayed that way. 25 , Q. Okay. Now, is it possible to put these . ' WHEELER REPORTING COMPANY. INC.'. 404..351 -4577 ' 43 (Pages .166 to 169)