Document J3N9Ox40Nv27g9w68rJQnvXyZ

ROGER HOBBIE Page 58 Page 60 1 also had the Ford Motor account in Detroit, Dearborn and 1 A Okay. 2 Louisville and Canada. 2 Q Do you recognize that document? 3 Q I think there is one more? 3 A Yes. 4 A Jack Murray had - the OEMs were Western Star which 4 Q Can you describe what it is? 5 was a smaller OEM at that time, Kenworth, Freightliner, 5 A Basically a communication from Jim Clark who was I 6 Peterbilt Volvo had an operation in Ogden, Utah evidently 6 think the chief brake engineer at that time, September 1986. 7 Jack called on. The rest of these are smaller trailer 7 He was I believe, Tom Bruggeman, I believe he was in the 8 manufacturers and crane manufacturer appears specific. And I 8 scheduling department, production scheduling and in a chain 9 would say they are probably a specialty equipment 9 somewhere. I guess he was located in Galesburg. But I think 10 manufacturer. 10 Jim was just alerting people ofthe fact of being carefril not 11 Q Do you keep in touch with any ofthese individuals? 11 to give the truck manufacturers a specific cutoff deadline on 12 A Jim Mollard, I run across him at some industry 12 the asbestos linings because of some uncertainties ofcertain 13 function meetings, American Trucking Association, Maintenance 13 specifications being able to be replaced by nonasbestos at 14 Council meetings. He works for -- the last I knew, I think he 14 that time. 15 worked for Abex. Pretty sure it was Abex. 15 Q This is dated September 25,1986? 16 Q He worked for Eaton and then moved on at some point 16 A Right 17 to work for Abex? 17 Q The subject is nonasbestos phase-out, correct? 18 A Yes. 18 A Yes. 19 Q When was the last time you saw him; do you remember? 19 Q It reads, engineering is continuing to investigate 20 A Probably within the last year. 2 0 consequences of announced deadlines for the stoppage of 21 Q Do you know where he presently resides? 21 asbestos production by Abex and Carlisle. Correct? 22 A In the Detroit area. 22 A Yes. 23 Q Do you know if he is still working for Abex? 23 Q Now, specifically, it addresses a list attached to 24 A 1 don't know for sure but I would guess he still is. 2 4 this memo, correct? 25 Q Is there a way for you to find out Mr. Mollard's 25 A Yes. Page 59 , Page 61 j 1 address? 2 A Yes. 3 Q How would you do that? 4 A I have a list of members of the American Truckers 5 Association maintenance council. 6 Q Do you keep in touch or have you had any contact 7 with any ofthe other account executives listed in the 8 exhibit, for instance, Craig Arms? 9 A No, I haven't. 10 MR. BARTELS: I will follow this up, Harry, 11 but I'm going to request that he produce Mr. Mollard's 12 address. 13 MR. QUICK: Do you want to pay him to do it? 14 A It's confidential information, I have to get ATA's 15 permission. 16 Q Oh, you do? 17 A No, just kidding. 18 MR. QUICK: Do it with a letter so 1 can 19 followup. 20 Q I would like to mark this as the next exhibit 21 (Exhibit 10, internal correspondence-9/25/86, 2 2 was marked for identification.) 23 MR. QUICK: For those of you on the phone, it 2 4 looks like Pat is getting near the bottom ofthe stack. 25 Q This isHobbie 10. 1 Q Apparently, the memo reads as follows, based on the 2 attached list, Navistar has requested all current brake 3 assemblies using asbestos linings to be provided (via 4 stockpiling, if necessary) through 1987. 5 A Correct, yes. 6 Q It also talks about applications that have not been 7 currently having nonasbestos materials will require continued \ 8 supply of asbestos products through 1988, while test programs 9 are completed? 10 A Correct 11 Q Navistar has requested stockpiling for asbestos 12 linings to be used through 1987, correct? 13 ALL COUNSEL: Objection to the form. 14 A That's correct 15 Q It also looks like they are continuing the testing 16 of nonasbestos materials and they don't anticipate that they 17 will be in a position to replace the nonasbestos materials 18 until some time through 19887 19 A Correct 1 think he was speaking from his best 20 knowledge ofthe whole situation, I think. 21 Q And now, attached is what appears to be a pretty 2 2 detailed listing of Eaton parts used by International 2 3 Harvester; is that correct? 24 A It looks like it, yes. 25 Q Apparently, these are lists of all current brake 16 (Pages 58 to 61) (800) MERRILL LEGAL SOLUTIONS 325-3376 www.MerrillCorp.com 5cfe6bcd-afe7-469e-b187-bOB1 ecda30a3