Document GzXrJ772G9Be89B6Ybn5KLwp4

Marcella Duncan 7-22-04.txt 18 THE WITNESS: HE'S THE SALES MANAGER FOR OUR 19 VICTOR REINZE VALVE SEALS. 20 BY MR. FISHBACK: 21 Q. WHERE'S THAT FACILITYLOCATED? 22 A. AVILLA INDIANA. 23 q! DO YOU'HAVE REGULAR CORRESPONDENCE WITH 24 MR. LEHMANN? 25 A. OH, YES. 0157 1 Q. THE SAME WITH MR.JOHNSON? 2 A. NO. 3 Q. DO YOU KNOW FOR HOW LONG MR. LEHMANN WORKED IN 4 THE PARTS CRAFT DIVISION? 5 A. NO. 6 Q. DO YOU KNOW HOW LONG MR. JOHNSON WORKED IN THE 7 PARTS CRAFT DIVISION? 8 A. NO. 9 Q. DO YOU KNOW WHAT THEIR SPECIFIC 10 RESPONSIBILITIES WERE IN TERMS OF WHEN THEY WORKED IN THE 11 PARTS CRAFT DIVISION? 12 A. NOT SPECIFIC. 13 Q. DO YOU KNOW IF THE SALES FORCE IN THE PARTS 14 CRAFT DIVISION WAS ORGANIZED BY CUSTOMER OR BY -- IN SOME 15 OTHER FASHION SUCH AS LOCATION? 16 A. THEY WERE REGIONAL SALES AND DISTRICT SALES. 17 THAT'S ALL I KNOW. 18 Q. DO YOU KNOW WHERE MR. JOHNSON'S REGION OR 19 DISTRICT WAS? 20 A. NO. 21 Q. DO YOU KNOW WHERE MR. LEHMANN'S REGION OR 22 DISTRICT WAS? 23 A. INDIANA OR OHIO AREA. INDIANA, I BELIEVE. 24 Q. DO YOU KNOW HOW MANY SALES PERSONS THERE WERE 25 PER REGION OR DISTRICT? 0158 1 A. NO. 2 Q. WHO WAS IN CHARGE OF THE PARTS CRAFT DIVISION? 3 A. I DON'T KNOW THAT I REMEMBER. I DON'T 4 REMEMBER. 5 Q. THERE'S LIKELY A RECORD THAT INDICATES WHO WAS 6 IN CHARGE OF THE PARTS CRAFT DIVISION DURING THE '59 AND 7 '80 TIME PERIOD, ISN'T THERE? 8 A. THERE'S HISTORY SOMEWHERE I WOULD THINK. 9 Q. DO YOU KNOW WHEN -- IS THERE STILL A PARTS 10 CRAFT DIVISION? 11 A. NO. 12 Q. WHEN DID IT CEASE TO BE OPERATIONAL? 13 MR. PARKER: ASKED AND ANSWERED. TO THE 14 EXTENT THAT YOU REMEMBER, GO AHEAD. 15 THE WITNESS: IT WAS IN THE 1990'S, SOME TIME. 16 BY MR. FISHBACK: 17 Q. DO YOU KNOW WHY IT CEASED TO OPERATE? 18 A. NO. 19 Q. OR EXIST? 20 A. NO. 21 Q. YOU WOULD MENTION THAT THERE WAS SOMETHING 22 CALLED A NATIONAL ACCOUNTS DIVISION? 23 A. YES. 24 Q. DO YOU KNOW WHEN THE NATIONAL ACCOUNTS DIVISION 25 WAS STARTED? 0159 1 A. ALL I REMEMBER IT WAS AFTER DANA ACQUIRED 2 VICTOR. Page 66