Document MMRwq7ZbJyg7Yb5GngdENo7Ma

Marcella Duncan 7-22-04.txt 25 A. YES. 0038 1 Q. AND YOU PULL OUT THE CARD THAT SAYS F.S. 1178. 2 WHAT KIND OF -- IS THAT RIGHT? 3 A. YES. 4 Q. WHAT KIND OF INFORMATION WOULD BE RECORDED ON 5 THAT CARD? 6 A. JUST THE NUMBER, THE PART NUMBER, AND THEN YOU 7 WOULD HAVE A COLUMN FOR RECEIPTS AND THEN A COLUMN FOR 8 SALES AND THEN A BALANCE COLUMN. 9 Q. ALL RIGHT. SO ON THE COMPUTER PRINTOUT, IT 10 WOULD TELL YOU WHETHER YOU WERE TO RECORD A RECEIPT OR 11 WHETHER YOU WERE TO RECORD A SALE? 12 A. YES. 13 Q. AND THEN YOU WOULD JUST LOG IT ON THE F.S. 1178 14 CARD FILE; CORRECT? 15 A. YES. 16 Q. AND THEN YOU'D GO ON TO THE NEXT ONE? 17 A. YES. 18 Q. AND THAT'S IT? 19 A. YES. 20 Q. YOU DID THAT FOR TWO YEARS? 21 A. YES. 22 Q. AND SO IF YOU WEREN'T FAMILIAR WITH THE PART 23 NUMBERS THEN, YOU DIDN'T KNOW WHAT THE PRODUCT WAS? 24 A. YES. 25 Q. AND SINCE I'M GUESSING THAT -- WELL, 35 OR SO 0039 1 YEARS THAT YOU'VE BEEN AT DANA? 2 A. YES. 3 Q. YOU'VE BECOME FAMILIAR WITH SOME OF THE PART 4 NUMBERS NOW? 5 A. YES. 6 Q. AND HAVE YOU HAD AN OPPORTUNITY TO GO BACK AND 7 REVIEW SOME OF THE CARD FILES OR THOSE COMPUTER PRINTOUT 8 PAPERS ABOUT WHAT KIND OF INVENTORY DANA CORPORATION HAD 9 BACK IN 1968 TO 1970 WHEN YOU WERE WORKING AS A RECORDS 10 CLERK? 11 MR. PARKER: I'LL OBJECT AS VAGUE. BY 12 "INVENTORY," WHAT KIND OF INVENTORY SYSTEM THEY HAD? 13 SHE'S TESTIFIED TO THAT. 14 BY MR. FISHBACK: 15 Q. WHAT KIND OF INVENTORY THEY HAD? WHAT KIND OF 16 MATERIALS THEY HAD? 17 A. THROUGH WORK EXPERIENCE. IN LATER YEARS THE 18 NUMBERS THAT I WORKED WITH THEN HAVE BECOME MORE 19 MEANINGFUL AS FAR AS WHAT PRODUCT IT REPRESENTED. 20 Q. WAS THERE A PARTICULAR -- YOU REMEMBERED 21 F.S. 1178. WAS THAT ONE THAT YOU RECALL SEEING COMMONLY 22 DURING THAT TIME? 23 A. THAT IS A VERY POPULAR ONE, YES. 24 Q. WERE THERE OTHER PART NUMBERS THAT YOU RECALL 25 AS BEING PARTICULARLY POPULAR THAT YOU SAW RECURRENTLY? 0040 1 MR. PARKER: HANG ON. I'M GOING TO OBJECT 2 NOW. THIS DEPOSITION IS SUPPOSED TO BE ABOUT GASKETS. 3 IT WAS SPECIFICALLY DECIDED THAT WE WOULD NOT BE GOING 4 INTO OTHER PRODUCTS. NOW YOU'RE GOING BEYOND HER 5 BACKGROUND AND ABILITY AND NOW YOU'RE GOING INTO OTHER 6 PRODUCTS, AND I'LL OBJECT ON RELEVANCY GROUNDS. AND IF 7 YOU PURSUE THIS LINE OF QUESTIONING, I'LL HAVE TO CUT IT 8 OFF. 9 GO AHEAD AND ANSWER THE QUESTION. Page 17