Document 93MGyk1j1K2N62wm0ga5n4GD5

Hicks, et al. v. ACandS, Inc., et al. ' 6/1/01 - Paul L. LeCour - Page 162 Page 164 1 2 3 4 .5 6 7 8 .9 10 11 . 12 13 14 15 16 1718 19 20 21 22 23 24 25 MR. DUMLER: 1 understand. (Plaintiffs' Exhibit LeCour 35 was marked.) Q. (By Mr. Dumler) I'm going to show you a document. Exhibit No. 35. It indicates NAPA through 1975. Have you ever seen this document before7 A. No. Q. Okay. This document refers to a.publication called NAPA Outlook. Your recollection is you don't have any recollection of seeing that document back in '75, NAPA Outlook? A. No. Q. Do you have any recollection of whether or not any of the hazards of asbestos were ever published in any of the NAPA Outlook? A. When'l was aware ofit, no. Q. What other publications do you get from NAPA? MR. RJLEY: Does he get from NAPA? Q. (By Mr. Dumler) Well, what other NAPA publications are you aware of? A. That's it. That's'the only thing that 1 know of. Q. Are you familiar with something called the NAPA Report? A. No. Q. Does Genuine Parts publish any newsletters or 1 to their customers. And basically it was a joke book. 2 There were jokes in it. It had some advertising in it. 3 Q. Anything else?' Any other publications that 4 were done by Genuine Pans disseminated to the jobbers 5 or others customers? 6 A. Not to my knuwledge. 7 Q. Mr. LeCour, in your Genuine Parts Answers to 8 Interrogatories, No. 167, it indicates that "Genuine 9 Parts may have received warnings from various suppliers 10 or vendors of friction product materials but cannot II' state the approximate date or content of the warnings." . 12 Do you ha ve any knowledge of any or the 13 warnings that Genuine Pans got from any supplier or 14 vendor of friction products? 15 A. No, I'm not aware of any. .16 Q. You indicated earlier that there were three 17 grades: professional, standard, and economy. Is that ' 18 generally correct? . 19 A. Yes. 20 Q. Was that the three grades that were available 21 between I960 and I9S0? 22 A. No. 23 Q. What was available between '60 and '80? 24 A. We had basically two. We had what we called 25 our B and RS with basically no name. Then we had our Page 163 Page 165 1 brochures or flyers or anything else that go out to its 2 customers? 3 A. What time period? ' 4 Q. Well, does it tlo it today? 5 A. Well, in an official magazine format or paper, 6 book format? They send out.promotional-materials all 7 the time. 8 - Q. But it doesn't have a newsletter or anything 9- like that it sends out to its customers? 10 A. To my knowledge, no. 11 Q. Has it ever - bfetweeri '60 and 'SO - between 12 `60 and today, is there a newsletter? 13 ' MR. RJLEY: VVell, 17) allow him to answer 14 the question, but I'm going to object that this 15 is beyond the scope ofyour list on your 16 Deposition Notice. So he can answer as to his 17 personal knowledge, but his answer is not as IS a person who's knowledgable of the company. 19 THE WITNESS: Parts Pick-Up. 20 Q. (By Mr. Dumler) I'm sorry? 21- A. Parts Pick-Up. 22 Q. What's the Parts Pick-Up? 23 . A. That was a little magazine (hat paid tribute 24 to a good dottier, jobber, operation. And this was 25 offered to all jubbers, that they could in turn give it 1 AB, called Stopper. 2 Then during that time frame, we called it 3' professional quality for the B and the RS. And Stopper 4 was alwaj's AB. 5 Q. What does the A and the B stand for in AB? 6 A. AB is American Brakeblok. 7 Q. Between 1960 and 1980, were al) of thr AB 8 brake shoes asbestos-containing? 9 A. Yes. . 10 Q. What does the B stand for? 11 A. Just the B only? 12 Q. Correct. 13 A. Bonded. 14 Q. Between I960 and 19S0, were oil the bonded 15 brake shoes usbcsios-coiitainiiig? 16 A. Yus. Well -- 17 Q. Go ahead. IS A.. Yuur question, all uT the BY.' 19 Q. Yes. 20 A. Yes. 21 Q. Is there a distinction? Is there some 22 B out there I'm noi thinking about? 23 A. Well, there was an M. 24 Q. Okay. 25 A. And that wns metallic. d 2 (Pages 162 to 16:) '-.'WHEELER REPORTING COMPANY, INC.,404.351-4577 . .