Document Mo7b0LB71kgqZnEwKverZkkak

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 use them interchangeably? 4 a. Yes. 5 Q.Okay. And yon - let roe read something to yon 6 here. When I asked to take this deposition, I . 7 asked for fixe person most knowledgeable regarding 8 the sale or supply of prodnets manufactured by 9 American Brakebloc, also known as Abex, and/or its 10 ' successor to or through the NARA distribution 11 centers,generally on the national level. Do you 12 feellxkc, in your business organization, you would 13 be the person who fits that bill? 1 over the bht plant, and I became plant manager, and 2 he was flying back and forth running both plants. 3 We had people like John Having, far example, who 4 was a Houston distribution center manager. We were 5 . talking to these people on a tegular basis bringing 6 in customers trying to get the business, and this 7 would be all the people in Dallas, and I'm talking 8 about in jobbing stores, NAPA parts stores, 9 Houston, San Antonio. 10 Q.Okay. Let me just go back to the knowledge you 11 have prior to 1966 that's not based on. your 12 personal knowledge? 13 A. Absolutely not 14 Al wouldn't say national because I'm not familiar 15. with the west coast at all. l Q.Okay. But, other than the west coast, yon feel 17 comfortable with that description? 14 Q. Could you do me --you had mentioned Karajobb< 15 the past and distribution centers. 16 a_Right. 17 Q. Could you provide me with kind of your 18 A.Yes. . 19 Q.Okay. 20 MR. (HanawSi That's alii have. Thanks. 21 . EXAMINATION 18 understanding of what a KARA distribution center 19 is, what a NAPAjobber is, and what the retail 20 store is, how that works, how that all works 21 together? 22 BY MR. ABBOTT 23 Q.Helin, Mr. Allen. My name is Ed Abbot. I 24 represent Pneumo-Abe* Corporation. I have just a 25 couple questions. 22 A. Let's start with the distribution center. Of 23 course, we used to call them warehouses back before 24 we went to distribution centers. These are people 25 that supply the nara parts stores for their Page 11 1 A-Okay. 2 Q.InitiaUy youjust mentioned something about 3 representing Rayloc. You're an employee of Rayloc, 1 2 3 4 is that correct? 4 5 A.Yes. 6 Q.Arc you employed by NAPA? 5 <f 7 Al'm employed by Genuine Parts Company. 8 Q.Are you employed by NARA? 7 8 9 A No, NAPA is a trade selling name. Genuine Parts . 9 10 Company is who I work for. 11 Q.You had mentioned before, prior to 1966, the 10 11 12 information you have prior to 1966, that was 13 obtained throng^ conversations you had with some 12 13 14 individuals? 14 15 A Walter Devoe, who was the plant manager there. 15 16 Q.Do you recall roughly when you had that 17 conversation? 16 17 18 AWell it's from'66 through'70. 18 19 Q.Okay, the last time you talked to Mr. Devon was 19 ' . Pa; particular locations, whether it be Kansas City, whether it be Dallas, Houston, San Antonio, all the . parts stores that are NAPA parts stores in those areas. The distribution brings in product from a lot of suppliers. They have -- they have engines, belts, hoses, remanufactured parts, numerous tilings, and they supply those exclusively to the Napa stores at that tune. The Napa stores, which could be a company owned or it could be an independent owned, they stocked ell of -what they considered to be a stock thatthey needed to supply thrir particular given area and this went out to dealers, it oould be individual walk-in trade, companies, anyone that. they were going to be doing business with. As far as the retail store, I don't think I'm knowledgeable enough about the retail store to talk about it. This is something that's fairly new as far as rhe super Stores. 20 1970 Ihen? 20 Q.t)ksy. 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 23' American Brakebloc, the relationships to Napa? 24 Q.Uh-huh. 25 A He became general manager approximately that time 21 that also the same as the terminology NAPAjobbes 22 AYes. . 23 Q.Okay. Now, the narajobbers they were not reqt 24 to purchase all of their materials from a NAPA 25 distribution center, is that correct? JOHN M. BOWEN & ASSOCIATES - (816) 421-2876 Page 10 - pa