Document 7R3174x3z4GMJn0Ynjq0zEajE
Marcella Duncan 7-22-04.txt
4 FOR THOSE CUSTOMERS HAVING BEEN DOING BUSINESS WITH
5 VICTOR DANA FROM REVIEWING THOSE MICROFICHE RECORDS;
6 CORRECT?
7 A. YES.
8 Q. SO OTHER THAN YOUR REVIEW OF THE MICROFICHE 9 RECORDS -- AND HOW MUCH DO YOU THINK YOU REVIEWED?
10 A. OH, MY GOD.
11 Q. YOU THINK THOUSANDS? 12 A. YES.
13 Q. HUNDREDS? 14 A. YES.
15 Q. YOUR REVIEWS OF THOUSANDS OF MICROFICHE 16 RECORDS, THAT YOU THINK THERE ARE MILLIONS; RIGHT?
17 A. NO. THERE'S 964,000 LINES OF DATA.
18 Q. AND YOU THINK YOU'VE REVIEWED THOUSANDS OF 19 LINES OF DATA?
20 A. UH-HUH.
21 Q. 10,000? 22 A. PROBABLY AT LEAST 10,000.
23 Q- MORE THAN 10,000?
24 A. (NO AUDIBLE RESPONSE.)
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Q. NOT SURE?
A. OH, YES. YES. IT HAS BEEN MORE THAN 10,000
2 BECAUSE JUST ON ONE EXERCISE ALONE I'VE REVIEWED 62,000
3 LINES OF DATA.
4 Q- WHAT WAS THAT IN CONJUNCTION WITH?
5 A. RAW MATERIAL SALES.
6 Q. WAS THAT FOR A CUSTOMER? DID YOU REVIEW THE 7 RECORDS FOR A CUSTOMER?
8 A. YEAH. UH-HUH.
9 Q. WHAT CUSTOMER WAS THAT?
10 A. THAT WAS FOR THE NAVY.
11 Q- DID VICTOR SUPPLY GASKETS TO THE U.S. NAVY? 12 MR. PARKER: I'LL OBJECT.
13 NO, YOU CAN ANSWER THAT.
14 THE WITNESS: WE SUPPLIED RAW MATERIALS, AND WE
15 SUPPLIED A FEW GASKETS AS WELL, YES.
16 BY MR. FISHBACK:
17 Q. WHAT DO YOU MEAN A "FEW," JUST ONE OR TWO?
18 A. NO. I WOULD SAY PROBABLY LESS THAN A DOZEN
19 DIFFERENT PART NUMBERS IS WHAT I WOULD SAY.
20 Q. DO YOU KNOW WHAT YEARS VICTOR DANA HAS BEEN 21 SUPPLYING GASKETS TO THE U.S. NAVY?
22 A. ON THE MICROFICHE RECORDS, THERE WAS SOME IN
23 THE '60S THAT I RECALL. SO I KNOW AT LEAST BACK IN THE
24 '60S, I REMEMBER THAT.
25 Q. SO THERE ARE, IN FACT, AFTERMARKET SUPPLIERS
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1 WHO YOU RECOGNIZE THAT DANA WAS -- DANA HAD AS CUSTOMERS
2 DURING THE YEARS 1958 TO 1980 -- 1959 TO 1980?
3 MR. PARKER: I THINK THE QUESTION -- THE THEME
4 IS FINE, BUT THE WORDS -- COULD YOU REPHRASE IT?
5 BY MR. FISHBACK:
6 Q. CAN YOU TELL ME THE NAMES OF COMPANIES THAT
7 VICTOR DANA WAS SUPPLYING GASKETS TO IN THE YEARS '59 TO
8 1980?
9 MR. PARKER: IN THE AFTERMARKET?
10 MR. FISHBACK: YES.
11 THE WITNESS: ONE OF THE COMPANIES WAS -- AND
12 THIS WAS FOR GOVERNMENT AFTERMARKET, WAS CALLED DEFENSE
13 INDUSTRY SUPPLY IN PHILADELPHIA, PENNSYLVANIA.
14 MR. PARKER: ARE WE TALKING AUTOMOTIVE?
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