Document Dvg72GeD61g3w9kmQXQeq7mEa

SEP. 13.2004 2:59PM RWDM LAW FIRM Multi-PageTM NO. 653' P. 8 Page 22 Page 24 1 had American Brakebloo on the labels. 1 a.And it was I drink a big operation, machine shop . 2 Q.Back -- 2 and everything, they supplied the Air Farce base 3 A. So I have to assume it's all American Brakebloc 3 there, and he bad a lot of knowledge as far as NAPA 4 ' inside the box. 4 jobbers, and be tried to pass that an to me. 5 Q.Back at that time that Mr. Riley referenced prior 5 Q.Great 6 l the late 1980's, did you purchase any --were 6 MEL G1ANARXS: That's all I have. . 7 any purchases made of ftiction materials from other 7 MR.DKXEY: Pat?' 8 manufacturers? 8 MR. RILEY: Do you want to have him read? 9 A No. Abex was a good supplier to us. Urey had some 9 That's it 10 problems with like some disk pads later on as far 10 . MR. DICKEY: We will read and sign. 11 as just probably havingtoo much business, -weren't n 12 able to supply a few part numbers, but that was in 13 the'90's. We didn't have to go outside. 12 13 14 Q.But, again, just to recap, the NAPA stores 14 15 themselves they were not required to exclusively 15 16 carry products that come from the NAPA distribution 16 . 17 center? 17 18 ANo. 18 19 Q.So going into a store someone -- 19 20 A He's ab independent business person. There is no 20 21 contract. 21 22 Q.Surc. They would supply based upon the product 22 23 that was available and die like? 23 24 A.I assume If I was in business, if I couldn't get 24 . , | something from my primary supplier, I'd.try to find 25. 1 something I could sell. Page 23 1 Page 25 2 Q. Uh-huh. And that product may or may not be an Abex 2 3 line? 4 Al could not make a statement on that. 3 4 TBUSESsWaZCStACSf 5 MR. abbot. No further questions. 5. 6 EXAMINATION 6 ) ss. 7 BY MR. dANARIS: 7 COUNTY OF, ) 8 Q.Just to clarify, as long as the name NAPA was on . 8 9 the box, it would be your understanding that it 9 Subscribed and sworn to before 10 would be an Abex lining? 10 me this davof . 2004. ll A Yes. 11 12 Q.When we talk about historical knowledge, this is 12 13 stuff that you learned in your training, is that 13 14 right? 14 NOTARY FUBUC 15 AYes. 16 Q.Bcing trained to do the job that you've done since 15' My Commission Expires: 16 17 1966, yon wore taught by people who had been 17 18- involved in this business before you -- 18 19 AYes. . 19 20 Q.--about what had gone on, is that right? 20 21 AWalter Devoe, the plant manager, was - before he 22 came and started that plant there at Geoaut 21 (CASE: In Re: ALL SIMMONS FIRM CASES ON THE MAY 3, . 22 2004, TRIAL DOCKET rVS- AW- CHESTERTON, et aL) 23 Industries, be ran and operated die local NAPA 23 . i store, company owned, in Fort Worth, Texas. 24 i Q.Qkay. 25 . , Page 22-Page 25 JOB[N M. BOWEN & ASSOCIATES - (816) 421-2876