Document MGe6M8gO2w73YjO2QVgzzKBKM

THOMAS DICKSON Page 78 Page 80 | 1 there. 2 Q. So you would do about a hundred of these 3 schools per year? 4 A. That's a rough estimate, yes. 5 Q. You had indicated that Kenworth was the first 6 to adopt die ceramic lining. Are you aware of whether 7 they purchased organic materials after that point in 8 time in the late 70's? 9 DEFENSE COUNSEL: Objection, form. 10 A Because of the way the clutch is specified, 11 the OEM's had to produce whatever the end user would 12 specify. And I would -- I can't say for sure once 13 Kenworth made the change to ceramic whether they ever 14 produced other product, but I would guess they did 15 simply because of the customer base. 16 Q. Do you have any documentation that would 17 contain the date upon which Kenworth made the decision 18 to go with the ceramics as their primary product? 19 A No, I don't. 20 Q. And do you know the individual in Dana Corp. 21 who would have the West Coast sales that would know 22 that information? 23 A I would have to think about that a while only 24 because I don't -- my memory doesn't remember names 25 very well. 1 ceramics, 50 percent organics. Did there come a 2 period in time prior to 1983 when that ratio changed? 3 A. I think what I said was from the 70's -- the 4 early 70's to 1980 the ceramic product grew from a 5 very low percentage to around 50 percent of the 6 business, around 1980. 7 Q. Okay. 8 A. Those were forecasted figures. I didn't see 9 actual sales figures on them, but I feel they were 10 pretty close. 11 Q. And then the ceramics grew as the asbestos 12 was removed. If you compared the ceramics to 13 fiberglass, would it be true that the ceramics are 14 more in use today than the fiberglass ones, discs? 15 A. Yes. I think ceramics continued to grow, but 16 at a slower pace from 1980 to the present. 17 MR. SMITH-GEORGE: All right. That's all 18 the questions I have. Thank you. 19 MR. RADCUFFE: Anybody else on the phone? 20 MR. KATZ: I have one quick follow-up 21 question. This is Mr. Katz. 22 EXAMINATION OF THOMAS G. DICKSON 23 BY MR. KATZ: 24 Q. Can you testify whether Dana Corp. sold any 25 brake products to Peterbilt or Kenworth? j 3 Page 79 Page 81 1 Q. How did you -- what are you basing your 2 statement on that Kenworth at some point in time made 3 a decision to use ceramics as their primary 4 transmission material? 5 A. Well, when we -- when jve started the Mack 6 business on the East Coast with'that super-duty clutch 7 I talked about, that rapidly became a premium product 8 and a standard of the industry. And Kenworth was 9 always somewhat a leader in new products coming into 10 the industry that were being accepted well by fleets. 11 And Mack was using probably 70 percent ceramic with 12 that clutch, and sometime not too long after that 13 people started changing to it and Ijust recall that 14 Kenworth was one of the ones that changed in the 15 earlier part of that swing. 16 Q. Now, Mack, even though they had the 17 super-duty clutch, still used about 30 percent 18 organics on their trucks? 19 A I would say they probably used about 20 20 percent maybe. They used some standard ceramic, we 21 call it, which was -- didn't have as many ceramic 22 buttons on the disc as the super-duty did. 23 Q. When - you had indicated earlier that from 24 those sales records that you reviewed there was a 25 point in time where the sales were about 50 percent 1 MR. RADCLIFFE: Object to the form. 2 MR. SMITH-GEORGE: Object to form. 3 A I can't testify to that, no. I don't believe 4 they did, but I can't -- I can't say for sure. 5 Q. Okay. Who would have that information? 6 Would the West Coast representative have that 7 information? 8 A No. At that time -- at the time that we were 9 selling heavy truck product -- axles to the industry, 10 it was all being done out of the home offices. And 11 basically the heavy track product was the old 12 International Harvester axle that Dana purchased, and 13 most of it was sold to International Harvester. It 14 would have been sales in the late 80's or 90's that it 15 would even be possible for Kenworth to put one of the 16 axles in, and I really doubt whether they ever 17 engineered a Spicer axle into that vehicle prior to ,18 the late 90's, if they did at all. 19 MR. KATZ: Okay. Thank you, Mr. Dickson. 20 THE WITNESS: Uh-huh. 21 MR. SMITH-GEORGE: Just for a point of 22 clarification, was that question regarding brakes? 23 MR. KATZ: Yes. 24 MR. RADCLIFFE: That's what the question 25 was. j j j j j j Henjum Goucher Reporting Services 1-888-656-DEPO 21 (Pages 78 to 81)