Document LkrQ3LbggNm0gOENb8XbwZg5

SEP. 13.2004 2:58PM RWDM LAW FIRM Multi-PageTM NO. 653 P. 5 Page 10 Pag. 1 Abex, in your mind, are the same company? 2 A.Yes. 3 Q.You dsc them interchangeably? 4 A.Yes. 5 Q.Okay. And you -- let me read something to yon 1 over the BHT plant, and I became plant manager, and 2 he was flying back and forth running both plants. 3 We bad people like John Having, for example, who 4 was a Houston distribution center manager. We were 5 . talldng to there people on a regular ba$U bringing 6 here. When I asked to take this deposition, I . 6 in customers trying to get the business, sad this 7 asked for the person most knowledgeable regarding' 7 would be all the peopls in Dallas, and Pm talking 8 the sale or supply of products manufacturedby 8 about in jobbing stores, NAPA parts stores, 9 American Biakebloc, also known asAbex, and/or its 9 Houston, Saa Antonio. 10 successor to or through tile NAPA distribution 10 Q.Okay. Let me just go back to the knowledge yon 11 ceaters generaUy on the national level. Do you 12 feel like, in your business organization, yoa would 11 have prior to 1966 that's not based on your 12 personal knowledge? 13 be the person whn fils that bill? 13 AAbsolutely not 14 AI wouldn't say national because I'm not familiar 14 Q. Could you do me -- you had mentioned NAPAjobb* 15. with the west coast at alL 16 Q. Okay. Bur, other than the west coast, you feel 15 the past and distribution centers. 16 A.Right. ' 17 comfortable with that description? 17 Q. Could you provide me with kind of your 18 A. Yes. . 18 understanding of what a NAPA distribution center 15 Q.Okay. 19 is, what a NAPAjobber is, and what the retail . 20 MR. gianariSi That's all I have. Thanks. 20 store is, how that woxks, how that all works 21 . EXAMINATION 21 together? 22 BY MR. ABBOT; 23 Q.Hello, Mr. Allen. My name Ls Ed Abbot. I 24 represent Pneumo-Abcx Corporation- I have jost a 22 A Let's start with the distribution center. Of 23 course, we used to call diem warehouses back before 24 we went to distribution centers. These are people 25 couple questions. 25 that supply ihe Napa parts stores for their 1 A Okay. Page 11 1 ' Pai particular locations, whether it be Kansas City, 2 Q.InitiaUy youjust mentioned something about 2 whether it be Dallas, Houston, San Antonio, all the 3 representing Raylop. You're an employee of Rayloc, 3 . parts stores that are napa parts stores in those 4 is that correct? 4 areas. The distribution brings in product from a 5 AYes. 6 Q.Arc you employed by NAPA? 5 lot of suppliers. They have -- they have engines, <1 belts, hoses, reroanufectorod parts, numerous 7 A I'm employed by Genuine Parts Company. 7 things, and they supply those exclusively to the 8 Q.Are you employed by NAPA? 9 A No, NAPA is a trade selling name. Genuine Parts . 8 napa stores at that time. 9 The Napa stores, which could be a cosqrcny 10 Company is who I work for. 10 owned or it could be an independent owned, they 11 Q.You had mentioned before, prior to 1966, the 11 stocked all of what they considered to be a stock 12 information you have prior to 1966, that was 12 that they needed to supply their particular given 13 obtained through conversations you had with some 13 area and this went out to dealers, it could be 14 individuals? 14 individual walk-in trade, companies, anyone that 15 AWalter Devoe, who was die plant manager there- 15 they were gang to be doing business wiih. 16 Q.Do you recall roughly when you had that 16 As far as the retail store, I don't think 17 conversation? 18 AWell, it's from '66 through '70. 19 Q.Okay, the last time you talked to Mr. Devoe was 17 I'm knowledgeableenough about the retail store to 18 talk about it. This is something that's fairly new 19 as far as the super stores. 20 1970 then? 20 Q.Dkay. You've made a reference to napa stores. 21 aNo. Are you talking about, when we're talking 22 about the information, we're talking about napa 21 that also toe same as toe terminology NAPAjobbe; 22 AYea 23 American Biakebloc, the relationships to Napa? 23 Q. Okay. Now, the NAPAjobbers they were not reqt 24 Q.Uh-hnh. 24 to purchase all of their materials from a napa 25 AHe became general manager approximately that tune 25 distribution center, is that correct? JOHN M. BOWEN & ASSOCIATES - (816) 421-2876 Page 10 - Pa