Document LgxbK1yo2DXGVO5GzRK9m9Yzz

1. The current training provided to FORD MOTOR COMPANY, automobile mechanics about asbestos during automobile servicing including, brake and clutch repair and replacement; 2. The current training provided by FORD MOTOR COMPANY dealerships to automobile mechanics during automobile servicing including, brake and clutch repair and replacement; . 3. The current training provided to FORD MOTOR COMPANY employees about asbestos, 4. Ford STARS training information, provided to FORD MOTOR COMPANY technicians. Upon oral examination before a Notary Public authorized by law to take depositions in *0 the State of Michigan. The oral examination will continue from day to day until complete. The videotaped deposition of the witness is being taken, for use at trial or for such other purposes as are permitted under the roles of court This also constitutes a Subpoena Duces Tecum, as authorized by Fla. R. Civ. P. 1.410 (e), compelling the designated witness to produce those documents and things described in Schedule `A" attached hereto. v DATED: AUGUST 4,2006 I '' ' ! THE FERRARO LAW FIRM ! Attorneys for the Plaintiff 4000 Ponce de Leon Boulevard, Suite 700 Miami, Florida 33146 (305^325^111 ^ , DAVID A, JAGOLINZER, ESQ. Florida Bar No.: 181153 CASE A DAM, ESQ Florida Bar No. 756091 2