Document 5bO9pOpLX7eoa09BeLReX2qE4

Marcella Duncan 7-22-04.txt 3 Q. YES. 4 A. MAY I RESTATE THAT? 5 Q. SURE. 6 A. THOSE SALES RECORDS GO BACK TO VICTOR 7 MANUFACTURING GASKET COMPANY BEFORE DANA ACQUIRED THE 8 COMPANY, WHENEVER THE DEAL WAS MADE THERE. 9 Q. SO -- 10 A. SO THOSE SALES RECORDS WOULD ENCOMPASS SALES TO 11 ALL CUSTOMERS, TO VICTOR MANUFACTURING GASKETS REGARDLESS 12 OF IF IT WAS O.E.M., SERVICE, AFTERMARKET, DISTRIBUTION, 13 WHATEVER. 14 Q. WHAT YEARS DID THE MICROFICHE SALES RECORDS 15 COVER? 16 MR. PARKER: ASKED AND ANSWERED. 17 BUT GO AHEAD. 18 THE WITNESS: THEY COVER UP TO ABOUT 1983. 19 BY MR. FISHBACK: 20 Q. AND DATING BACK HOW FAR? 21 A. WE'VE NEVER REALLY KNOWN THE VERY FIRST DATE. 22 BUT I CAN TELL YOU IT GOES BACK INTO THE EARLY 1940'S. 23 WE'VE SEEN SOME OF THOSE DATES. 24 Q. AND AT SOME --AT SOME POINT, DOES THE 25 INFORMATION CONTAINED ON THE MICROFICHE SALES RECORDS 0097 1 CHANGE SO THAT IT ONLY REFLECTS SALES TO O.E.M.? 2 MR. PARKER: LACKS FOUNDATION, CALLS FOR 3 SPECULATION ON HER PART. 4 THE WITNESS: WHEN? 5 MR. PARKER: IF YOU KNOW. 6 THE WITNESS: THIS ISN'T DUST A YES OR NO. I'M 7 SORRY. 8 MR. PARKER: THAT'S OKAY. IT'S ONLY IF YOU 9 KNOW. 10 THE WITNESS: I DO KNOW. 11 MR. PARKER: 1OKAY. 12 MR. CORCORAN: JOIN IN THE FOREGOING 13 OBJECTIONS. 14 THE WITNESS: IN THE LATE 1960'S, WHEN DANA 15 ACQUIRED VICTOR, VICTOR PRODUCTS DIVISION SALES WERE TO 16 THE O.E.M. AND O.E. SER' CLCE. THE AFTERMARKET SALES 17 CUSTOMERS WERE HANDLED 1 JY A DIFFERENT DIVISION. SO THOSE 18 SALES RECORDS WOULD NOT BE ON THE MICROFICHE FROM ABOUT 19 1967 TO THE TIME THAT THE MICRO -- THE SALES CARDS WERE 20 NO LONGER USED IN APPROXIMATELY 1983. 21 BY MR. FISHBACK: 22 Q. PRIOR TO DANA CORPORATION'S ACQUISITION OF 23 VICTOR, THEY MICROFICHED SALES RECORDS. 24 A. ALL THE SALES OF MANUFACTURING GASKETS TO ANY 25 OF THEIR CUSTOMERS, CORRECT. 0098 1 Q. YOU REFERENCED SOMETHING THAT I WANT TO BE -2 I NEED TO CLARIFY; THAT IS, O.E.M., ORIGINAL EQUIPMENT 3 MANUFACTURER; CORRECT? 4 A. YES. 5 Q. AND YOU SAID O.E. SERVICE? 6 A. YES. 7 Q. WHAT DOES THAT MEAN? 8 A. MOST OF THEBIGORIGINAL EQUIPMENT 9 MANUFACTURERS. 10 Q. WHO DO YOU INCLUDE IN THAT CATEGORY BY THE WAY? 11 MR. PARKER: ONE QUESTION AT A TIME. LET HER 12 FINISH THE FIRST QUESTION. 13 BY MR. FISHBACK: Page 41