Document DDKOrdew72MJDM73K92RvGp6a

Marcella Duncan 7-22-04.txt 7 MR. PARKER: CAN YOU SPELL THAT FOR THE RECORD. 8 THE WITNESS: V-I-V-I-R-I-T-O. 9 BY MR. FISHBACK: 10 Q. AND WHAT'S HER POSITION NOW? 11 A. INTERNATIONAL SALES ADMINISTRATOR AND SALES 12 ANALYST )R ME. SHE WORKS FOR ME. 13 Q- DO YOU KNOW WHAT SHE DID FOR MR. KOERNER? 14 A. I BELIEVE SHE WAS THE SALES SECRETARY AT THAT 15 TIME. 16 Q. IS THERE SOMEONE THAT YOU KNOW WHO'S BEEN IN 17 THE SALES DEPARTMENT LONGER THAN MISS VIVIRITO? 18 A. SALES OPERATIONS DEPARTMENT? 19 Q. YES. 20 A. MY DEPARTMENT, NO. 21 Q. IS THERE SOMEONE IN THE COMPANY IN DANA 22 ANYWHERE 23 BEEN WITI 24 A. THAT'S BEEN IN THE VICTOR SALES OPERATIONS? 25 0218 Q- YES. AND MY THINKING IS THAT MAYBE THEY WERE 1 AT THE SALES OPERATION AND WENT SOMEWHERE ELSE BUT HAVE 2 BEEN WITH THE COMPANY FOR HOWEVER LONG? 3 A. I UNDERSTAND. 4 I DON'T THINK SO. 5 Q. WHAT CITY DOES MISS VIVIRITO WORK IN? 6 A. IN LISLE. 7 Q. IN LISLE. DOES SHE LIVE IN THE AREA AS WELL? 8 A. YES. 9 Q. WHAT CITY DOES SHE LIVE IN? 10 A. WOODRIDGE. 11 Q. WOODRIDGE. SO IS THERE ESSENTIALLY NO WAY TO 12 ASCERTAIN THE DOLLAR AMOUNT OF TOTAL PURCHASES MADE BY A 13 PARTICULAR CUSTOMER FOR THE YEARS 1959 TO 1980? 14 MR. PARKER: I'M GOING TO OBJECT AS VAGUE AND 15 AMBIGUOUS AS PHRASED AND LACKS FOUNDATION. 16 TO THE EXTENT YOU CAN ANSWER THAT, GO AHEAD. 17 THE WITNESS: I DO NOT KNOW. 18 BY MR. FISHBACK: 19 Q. DO YOU KNOW WHAT THE DOCUMENT RETENTION POLICY 20 IS FOR ACCOUNTING DOCUMENTS? 21 A. NO. 22 Q. WHO'S IN CHARGE OF THE ACCOUNTING DEPARTMENT, 23 ACCOUNTS RECEIVABLE? 24 A. AT CORPORATE HEADQUARTERS THE DIRECTOR OF -- 25 IT'S CORPORATE CREDIT, I'M SORRY, IS THE NAME OF THE 0219 1 GROUP. 2 Q. OKAY. 3 A. THEIR DIRECTOR OR THE HEAD OF THAT GROUP, HER 4 NAME IS LAUREN ANDERSON. 5 Q. I THINK YOU'VE GIVEN ME HER NAME BEFORE, I 6 APOLOGIZE. WE'LL TURN BACK TO THE CUSTOMER ISSUE IN A 7 COUPLE OF MINUTES, BUT I NEED TO DIGRESS TO GET SOME MORE 8 INFORMATION ABOUT YOUR EXPERIENCE IN DANA. 9 AND YOU SAID THAT YOU WERE IN THE SEALING -- 10 YOU WERE THE INVENTORY RECORDS CLERK IN CHURUBUSCO FROM 11 1968 TO 1970. 12 WHAT DID YOU DO AFTER THAT? 13 A. I WAS AT THE SERVICE PARTS OPERATIONS DIVISION 14 FOR THREE YEARS TOTAL. I HELD THE INVENTORY RECORDS 15 CLERK POSITION, STAGING AREA CLERK'S POSITION, AND SENIOR 16 INVENTORY RECORDS CLERK IN THAT FACILITY. 17 Q. LET ME BREAK IT DOWN. WHAT WAS THE NEXT Page 91