Document 87pBvK4wOQOLn0bGoRopOvwe

ROGER HOBBIE Page 74 Page 76 1 Q When you were at Eaton during this time frame, do 2 you recall Eaton making arrangements to stockpile excess 3 asbestos brake linings in anticipation of Carlisle and Abex 4 discontinuing the manufacture of asbestos-containing brakes? 5 A I was not personally aware of that. Although I 6 would say that knowing situations where somebody was going to 7 phase out a product that was supplied to us, that in order to 8 keep from having to shut down production and not be able to 9 ship our products to our customers, that, yeah, that was a 10 practice that would be, you know, performed to meet that 11 standard. 12 Q A couple more, the next exhibit, please. 13 (Exhibit 16, letter-11/21/86, was marked for 14 identification.) 15 Q 1 will show you what's been marked as Hobbie 16. I 16 will show that to Harry. 17 A Okay. 18 Q Have you had a chance to look at that document? 19 A Yes. 20 Q Can you describe what it is? 21 A Eaton axle brake purchasing, the principal buyer 2 2 communicating to Mr. Robert Kickel, vice-president, OE sales 23 for Motion Control. 24 Q What is the date ofthe letter? 25 A November 21, 1986. 1 and not cause a shortage to stop production. 2 Q Again, during the time that you were at Eaton, do 3 you have a recollection of Eaton entering into agreements with 4 either Abex and/or Carlisle to provide materials in a 5 stockpile setting beyond the date that they stopped their 6 production of asbestos products? 7 A No. J was not specifically aware of that, again 8 going back to what standard practices would have been to 9 ensure that there was a flow, a continuous flow for production 10 to not shut down the plants. 11 (Exhibit 17, letter-12/19/86, was marked for 12 identification.) 13 Q I will show you Hobbie 17. I will give that to' 14 Harry. 15 A Okay. 16 Q What is that document? 17 A It's from Tom Bruggeman, the purchasing guy at axle 18 brake division, to Milt Barnhart who was at the time December 19 19, 1986 the Eaton axle brake account manager for 2 0 International Harvester. This looks to me like he is 21 referring to this stockpile situation and that Navistar, 2 2 International Harvester, had signed a supply contract with 2 3 Rockwell, the brake competitor, and there was concern that the 2 4 production usage by International of the Eaton brake may drop 2 5 off enough that this whole stockpile thing would just be Page 75 Page 77 1 Q Who is it from specifically? 2 A From Thomas Bruggeman, principal buyer, Eaton axle 3 brake division. 4 Q There is a cc. listed at thebottom? 5 A Yes. 6 Q Do you recognize any ofthe names7 7 A Yes. 8 Q Could you outline who you know? 9 A Tom Sheikh was the sales representative from Motion 10 Control to Eaton. George Cotter, general manager of the axle 11 brake division. Fred Kovalik I think at the time was probably 12 materials control manager or operations manager, I forget 13 which, for Eaton. Bill Hoenes, again engineering manager, 14 axle brake. Robert file, purchasing manager, axle brake. 15 Gopel Singh, he was overall chief brake engineer, brake 16 products. 17 Dennis Bryant I think was a schedu ler out of 18 the Henderson, Kentucky plant; Jim Clark, chief engineer 19 axle - brake product; John Lilly, internal sales. Larry 2 0 Singewalt was a sales coordinator at the axle brake division. 21 Q What is your understanding of what is being asked of 2 2 Motion Control in that letter? 2 3 A It appears to me they were being asked to meet their 2 4 original commitment they had made about supplying enough 2 5 material to meet the needs, i.e., stockpiling some material 1 sitting there not used. That's what I would say it is. 2 Q At any time while you were with Eaton during this 3 time frame, between '84 and '88-'89 time frame, did you ever 4 become aware of Eaton basically being stuck with excess 5 asbestos materials? 6 A No. I would say no, at least from my perspective in 7 my frmction, when we switched over to nonasbestos, like for 8 field applications, we were never trying to sell asbestos as a 9 replacement or anything like that. We were basically going to 10 nonasbestos and that was what we did. We didn't drag asbestos 11 out of the woodwork or anything. 12 Q I understand what you are saying. Do you know if 13 prior to Eaton going completely nonasbestos if they had any 14 leftover asbestos materials? 15 A I don't know that for sure. There may have been but 16 it wasn't like they had a fire sale or anything that I was 17 aware ofto get rid of it or anything like that. I don't know 18 how it was disposed of or what happened to it. 19 MR. BARTELS: Mr. Hobbie, thank you very much. 20 MR QUICK: He will read. 21 MR. BARTELS: Anybody else have any questions? 22 BY MR HAFNER: 23 Q Bob Hafner, I have a few follow-ups. Mr. Hobbie, I 24 do not have the document in front of me, but do you have 2 5 Exhibit 8 there you can look at? 20 (Pages 74 to 77) (800) MERRILL LEGAL SOLUTIONS 325-3376 www.MerrillCorp.com 5cfe6bcd-afe7-469e-b187-b081ecda30a3