Document DGvq4pdRXrkZ2kkxep8rzNRYa

`SEP. 13.2004 2:58PM RWDM LAW FIRM Multi-Pagettf NO. 653 P. 6 Page 14 Page 16 l A. No, there was no contract that I know of. 1 like, were selling products that did come from 2 Q.They were free to purchase brake linings from other 2 areas outside of distribution centers? 3 manufacturers other than Abcx7 3 AWell, that was part of our business to go in and- 4 A. They could, but most of them didn't or any of the 4 if someone was buying water pumps, for example, 5 remanufacmred parts. 5 we'd try to get their business and bring them into 6 Q.Okay. 6 our plants end show them how we produced the units 7 (OFF-THEHRJ8CORD DISCUSSION.) 7 and, if they were not buying our water pumps, 8 Q.Just a couple more questions. 'When an individual 8 hopefully we could get their business, this was an 9 walked into a retail store and purchased brakes, 9 ongoing deal, there was stores that would be not a 10 they would not necessarily be purchasing Abac brake 10 NAPA-not a Napa store that would be selling any 11 lining, is that correct? 11 kind ofproduct that we were trying to get their 12 A. During what time frame? 12 business; but the NAPA Stores that I was in and any 13 Q.Let's take your historical understanding prior.to 13 of these changes like water pump changes is always 14 1966. 14 American Brakebloc. - 13 A they would be purchasing Abex material. 15 Q.Was there a time, in your opinion, that it was not. 16 Q.In any retail store? 16 American Brakebloc, American Brakebloc was not the 17 AYes, ray understanding, yes. 17 only supplier of brake linings? 18 Q.And what about the katajobbers? 18 Al would say late - late '80's, maybe early '90's. 19 Alhat's who we're talking about, the napajobbers. 19 Q.And the basis of that knowledge is what? 20 Q.Okay, but they were free not to -- but the napa 20 A Well, BPI became rhe primary supplier I believe the 21 jobbers yonjust said -- 21 year was 1989. 22 Athey were free to purchase water pumps or anything 22 Q.Did Genuine Parts manufacture its own line of brake 23 else from somebody else if they so choose, but most 23 linings? 24 of diem are ail loyal. Abex was a long time 24 A They don'Mnanufacture brake linings. supplier, and they were a good supplier. We still 25 Q.Okay. Tell me about Rayioc brakes, did they . Page 15 Page 17 1 use them today as our supplier at Morganfield, 1 manufacture their omi bate linings? 2 Q.Okay, so then, after 1966 if someone walked into a 2 MB-ULBYi You said bate Usings. 3 NAPA store and purchased brake linings, would they 3 ' MB. ABBOT: l Mid, I'm Sony? 4 necessarily be purchasing Abex brakes? 4 MR. RILEYi You said fliey manufactured 5 Ain my opinion, it would be Abex in the NaPaboxes, 5 brake linings- He said they don't maanfnetate 6 yes. 6 brake linings. 7 Q.And the basis of that opinion is what? 7 Q.(aymr. abbot) Brahe*? - 8 AWhat I've been told by Walter Devon and all the 8 A Btiokvp to yonr original question. 9 people that I've associated with when I went to the .9 Q-Strite that. Gjrc me troo second, I'm Sony. 10 .Stephenville plant 10 ' Are you familiar with agentlemen named 11 Q.Again, you have so independent knowledge of that? 11 Paul LaeonT? 12 ANo, six, I do not other than doing changeavers and 12 AYes. ' 13 stuff on other product lines. 13 Q. What was hisjeft title, u you understood it, the 14 Q.And stores that carried napa products, again, could 14 lost lime you s*v him or What was his job title? 15 sell other products as well, not just-- I'm not 13 A You mean the last time I saw him? 16 talking just brake linings-- 16 Q.Yes. 17 A Yes. 17 hOLdcxEYt Do you know his title? 18 Q.~ they could sell a variety of products? 18 AI don't really know. I'm going jo jay customer ' 19 AYes. . 19 . sendee, bot I'm not sow. It's changed over the ' 20 Q.Smne of those products could come from a NAPA 20 last lew years. K. ' 21 distribution center? 21 Q. (byNXabbot) Hew long have you known Mr. lacqnrl - 22 Ah's possible. 22 A. Since prebabty since '&4. 1 may have talked with 23 Q.And some of them did not? 23 him priortb. let's make fast like 19$0. '4 AYes, it's posable. 24 Q.Okay. ,J Q.Were you aware that napa stores, jobbers and the 23 A Because l bad some conversations I tirink with Paul Page 14- Page 17, JOHN M. BOWEN & ASSOCIATES - (816) 421-2876