Document M4g8BYQ24Z4bwRavR04zK224z

Marcella Duncan 7-22-04.txt 4 OPINION, WAS A LARGER CUSTOMER OF AFTERMARKET -- SINGLE 5 LARGER CUSTOMER OF AFTERMARKET SINGLE GASKET PRODUCTS 6 OTHER THAN NAPA? 7 A. NO. 8 Q. DO YOU KNOW WHO, IF THERE WAS ANY -- IF THERE 9 WAS A PARTICULAR CONTACT PERSON AT NAPA THAT DEALT 10 EXCLUSIVELY WITH THE VARIOUS SALES PERSONNEL AT VICTOR 11 DANA? 12 A. I -- 13 MR. GRAHAM: OBJECTION; ASSUMES FACTS. 14 I'M SORRY. I DIDN'T MEAN TO INTERRUPT. THIS 15 IS MICHAEL GRAHAM. 16 MR. PARKER: ACTUALLY, YOU DO MEAN TO INTERRUPT 17 THE WITNESS, AND THE WITNESS UNDERSTANDS THAT YOU MAY 18 HAVE OBJECTIONS AND SHE'LL TRY TO WAIT FOR THOSE TO BE 19 MADE BEFORE ANSWERING. I'LL JOIN IN THOSE OBJECTIONS. 20 GO AHEAD. 21 THE WITNESS: I DON'T KNOW. 22 BY MR. FISHBACK: 23 Q. THERE ARE OTHER AFTERMARKET PARTS STORES WHO 24 HAVE BEEN LARGE CUSTOMERS OF DANA OTHER THAN NAPA; 25 CORRECT? 0206 1 MR. PARKER: I'LL OBJECT AS TO THE WAY THAT YOU 2 CHARACTERIZED NAPA THERE A MOMENT AGO, AND IT LACKS 3 FOUNDATION BECAUSE SHE DOESN'T NECESSARILY JOIN IN THAT 4 SAME CHARACTERIZATION. 5 MR. GRAHAM: THIS IS MICHAEL GRAHAM. I'LL 6 JOIN, AND ALSO THAT THAT ASSUMES FACTS. 7 MR. PARKER: WHAT'S THE QUESTION AGAIN? 8 BY MR. FISHBACK: 9 Q. DO YOU HAVE THE QUESTION IN MIND? 10 MR. PARKER: IT LOOKS LIKE YOU'RE READING IT 11 OFF OF SOMETHING. 12 THE WITNESS: NO, NOT CLEARLY. 13 BY MR. FISHBACK: 14 Q. THERE ARE OTHER AFTERMARKET PART STORES WHO 15 HAVE BEEN CUSTOMERS OF THE DANA CORPORATION, VICTOR DANA 16 FOR AUTOMOTIVE GASKETS, OTHER THAN NAPA; CORRECT? 17 MR. PARKER: SAME OBJECTIONS. 18 HE'S JUST RE-READING IT. GO AHEAD. 19 THE WITNESS: YES. 20 BY MR. FISHBACK: 21 Q. WHO ARE THOSE? WHAT ARE THOSE? 22 A. THE ONES THAT COME TO MIND WOULD BE LIKE PARTS, 23 INC., OR PARTS PLUS I THINK THEY'RE ALSO CALLED. CAR 24 QUEST. 25 MR. PARKER: AND, AGAIN, WE'RE TALKING 1959 TO 0207 1 1980? 2 THE WITNESS: OH. I DON'T KNOW. 3 BY MR. FISHBACK: 4 Q. SO YOU DON'T KNOW WHO THE OTHER SUPPLIERS OR, 5 RATHER, YOU DON'T KNOW WHO THE OTHER LARGE CUSTOMERS OF 6 DANA CORPORATION FOR AFTERMARKET AUTOMOTIVE GASKETS ARE 7 DURING THE TIME PERIOD OF '59 TO '80 BESIDES NAPA? 8 A. NO. 9 MR. PARKER: MISCHARACTERIZES HER TESTIMONY 10 UNLESS SHE TESTIFIES IT'S NAPA. 11 BUT WHY DON'T WE CLARIFY IT FOR HIM SO YOU 12 DON'T WASTE TOO MUCH TIME ON THIS. 13 THE WITNESS: OKAY. FROM THE TIME I CAME TO 14 WORK IN 1968 UNTIL 1980, THE END OF THE TIME PERIOD HERE, Page 86