Document OEN84dG8vQQMXpLBj5J4Nv9xj

Marcella Duncan 7-22-04.txt 14 A. NO. 15 MR. PARKER: AGAIN, FOR THE RECORD, WE'VE 16 PREVIOUSLY REPRESENTED THAT WE HAVE A DIFFERENT WITNESS 17 FOR THOSE CATEGORIES. 18 BY MR. FISHBACK: 19 Q. DO YOU BELIEVE THERE IS ANYONE AT DANA 20 CORPORATION WHO HAS MORE KNOWLEDGE THAN YOU ABOUT THE 21 SUPPLY OF GASKETS BY VICTOR DANA TO NAPA INCLUDING ITS 22 STORES, NAPA JOBBERS, AND THE LARGER ENTITY OF NAPA? 23 MR. PARKER: FROM THE TIME PERIOD OF '59 TO 24 '80? 25 MR. FISHBACK: THAT'S CORRECT. 0288 1 MR. PARKER: WHO'S PRESENTLY WITH THE COMPANY. 2 THE WITNESS: I CAN'T THINK OF ANYONE. 3 BY MR. FISHBACK: 4 Q. AND YOU HAVEN'T DONE ANYTHING SPECIFIC TO 5 EDUCATE YOURSELF ABOUT THE SUPPLY OF VICTOR GASKETS TO 6 NAPA STORES FOR RETAIL SALE BY NAPA DURING THE YEARS '59 7 TO '80 WITH RESPECT TO DANA; IS THAT CORRECT? 8 MR. PARKER: VAGUE AND AMBIGUOUS. UNLESS YOU 9 MEAN TO PREPARE FOR THIS DEPOSITION? 10 MR. FISHBACK: I MEAN EXACTLY WHAT I SAID. 11 MR. PARKER: IT'S VAGUE AND AMBIGUOUS AS 12 PHRASED. 13 THE WITNESS: WOULD YOU SAY THAT AGAIN, PLEASE. 14 BY MR. FISHBACK: 15 Q. SURE. HAVE YOU DONE ANYTHING SPECIFIC TO 16 EDUCATE YOURSELF ABOUT THE SUPPLY OF VICTOR GASKETS BY 17 DANA CORPORATION, VICTOR DANA, TO NAPA STORES FOR RETAIL 18 SELL BY NAPA IN THIS PERIOD 1959 TO 1980? 19 MR. PARKER: SAME OBJECTIONS. 20 THE WITNESS: NO. 21 MR. FISHBACK: IT'S 5:20. 22 MR. PARKER: DO YOU WANT TO TAKE A SHORT BREAK? 23 MR. FISHBACK: I HAVE SOME OTHER BUSINESS TO 24 ATTEND TO AT 4:00 ON THE WEST COAST. SO I'M GOING TO ASK 25 A COUPLE MORE -- FEW MORE AREAS OF QUESTIONS FOR YOU, AND 0289 1 THEN I'LL RECESS THIS DEPOSITION AND CONTINUE WITH IT 2 WHENEVER I CAN, OR UPON WHATEVER MEANS IT TAKES TO 3 CONTINUE IT. 4 MR. PARKER: I DON'T HAVE A PROBLEM TO TAKE A 5 SHORT BREAK SO YOU CAN TAKE CARE OF SOME BUSINESS ON THE 6 WEST COAST. BUT WE'RE PREPARED TO STAY HERE BECAUSE YOU 7 SAID YOU NEEDED MORE TIME. YOU'VE INDICATED THAT YOU MAY 8 HAVE SOME DOCUMENTS TO SHOW HER. I UNDERSTAND THAT YOU 9 HAVE, SOME C.D.'S WITH YOU IN WHICH THOSE DOCUMENTS ARE 10 ON. WE'RE NOT GOING TO HAVE YOU RECESS IT AND THEN, SAY, 11 "SORRY, I HAVE TO COME BACK FOR ANOTHER FULL DAY." 12 MR. FISHBACK: COUNSEL, I UNDERSTAND YOUR 13 POSITION. 14 MR. PARKER: GOOD. 15 MR. FISHBACK: AND I'M TELLING YOU I'VE BEEN 16 MORE THAN REASONABLE IN ACCOMMODATING YOUR FLIP-FLOPPING 17 SCHEDULE SO -- 18 MR. PARKER: MY WHAT? 19 MR. FISHBACK: YOUR FLIP-FLOP SCHEDULE. 20 MR. PARKER: YOU SAID RIGHT BEFORE YOU WERE 21 GOING TO END FOR THE DAY EARLIER THAT YOU NEED A LOT MORE 22 TIME FOR THIS WITNESS. SO WE MADE HER AVAILABLE FOR A 23 LOT MORE TIME. 24 MR. FISHBACK: I UNDERSTAND, AND I'VE BEEN Page 120