Document 8R4NJgmXwd5yj4nNOO6goBydk

Marcella Duncan 7-22-04.txt 7 DID NOT HAVE ANY PRIOR KNOWLEDGE ABOUT THE COMPANY. 8 Q. OKAY. WHEN YOU FIRST WERE EMPLOYED OR GOT A 9 DOB WITH DANA CORPORATION IN 1968, WHAT WAS YOUR DOB 10 TITLE? 11 A. I WAS INVENTORY RECORDS CLERK. 12 Q. WHAT DOES AN INVENTORY RECORDS CLERK DO? 13 A. OKAY. I WORKED AT A PACKAGE AND DISTRIBUTION 14 CENTER, AND MY DOB WAS TO INDICATE ON THE INVENTORY CARD 15 RECORDS INCOMING MATERIALS AND OUTGOING MATERIALS TO KEEP 16 A RUNNING INVENTORY OF WHAT WAS ON HAND. 17 Q. HOW LONG DID YOU WORK AS AN INVENTORY RECORDS 18 CLERK? 19 A. TWO YEARS. 20 Q- SO UNTIL 1970? 21 A. YES. 22 Q. DURING THAT TIME 1968 TO 1970, DID YOU BECOME 23 FAMILIAR WITH THE PRODUCTS THAT WERE BOTH INCOMING AND 24 OUTGOING? 25 A. NOT REALLY. 0029 1 Q. I THINK YOU REFERRED TO AS INCOMING AND 2 OUTGOING MATERIALS. WHAT DO YOU MEAN BY "MATERIALS"? 3 A. PARTS. 4 Q. WERE THEY RAW MATERIALS? 5 A. NO. THEY WERE LIKE MADE COMPONENTS. 6 Q. SO THE FINISHED PRODUCT? 7 A. YES. 8 Q. AND WHAT FINISHED PRODUCTS WERE THEY? 9 A. AUTOMOTIVE PARTS FOR ENGINES, CHASSIS. IT WAS 10 PRODUCTS THAT WERE MADE BY OTHER DIVISIONS OF DANA 11 CORPORATION. 12 Q. AT THE -- WHAT CITY DID YOU FIRST START WORKING 13 AT AS THE INVENTORY RECORDS CLERK? 14 A. CHURUBUSCO, INDIANA, AND THAT'S 15 C-H-U-R-U -B-U-S-C-O. 16 Q. AND SO THIS WAS A MANUFACTURING FACILITY? 17 A. NO. 18 Q. PURELY DISTRIBUTION? 19 A. PACKAGING AND DISTRIBUTION. 20 Q. SO I THINK I UNDERSTAND HOW THAT WORKS, BUT 21 BASICALLY THE FINISHED MATERIALS WOULD COME INTO 22 CHURUBUSCO, INDIANA, THE FACILITY THERE, AND THEY WOULD 23 BE PACKAGED THERE AND THEN SHIPPED OUT TO WHOEVER THE 24 PURCHASER WAS? 25 A. CORRECT. 0030 1 Q. AND YOU SAID THERE WERE AUTO PARTS FOR 2 ENGINES. DO YOU REMEMBER ANY SPECIFIC TYPES OF AUTO 3 PARTS FOR ENGINES THAT WERE -4 A. GASKETS. 5 Q. OKAY. ANYTHING ELSE? 6 A. OIL SEALS. 7 Q. ANYTHING ELSE? 8 A. PISTON RINGS, HOSE, CAMSHAFTS, STUFF LIKE THAT. 9 Q. ANYTHING ELSE YOU CAN RECALL OTHER THAN THE 10 SPECIFIC ITEMS THAT YOU'VE MENTIONED? 11 A. VALVES, LIFTERS. 12 Q- WHAT'S A "LIFTER"? 13 A. WELL, I CAN TELL YOU WHAT IT LOOKS LIKE. BUT I 14 CAN'T TELL YOU WHAT IT DOES. 15 Q. THAT'S GOOD. 16 A. IT'S GOT LIKE A ROUND METAL, AND IT'S GOT A 17 STICK ON IT. THAT'S WHY WE CALL THEM LIFTERS. Page 13