Document QkyzOw3wRRBqNX8g6bXo56qRR
FILE NAME: Chrysler (CHRY) DATE: 1988 June 14 DOC#: CHRY149 DOCUMENT DESCRIPTION: Legal - Deposition of Jack L. Koblin
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SUPERIOR COURT OF NEW JERSEY
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LAW DIVISION{MIDDLESEX COUNTY
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DOCKET NO. L-095651-85
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MARSHALL COATES# t UX.,
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Plaintiffs
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vs
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RAYMARK INDUSTRIES# et al.#
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Defendants
DEPOSITION UNDER ORAL EXAMINATION
OP JACK L. KOBLIN
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IS
ROBERT CAMPBELL# et ux.#
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Plaintiffs#
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VB
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NATIONAL PARTS SUPPLY#
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Defendants
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duplicate
FILE COPY
b- 4-&
Brody a Geisec (201) 738-8555 or (212) 732-0644
KOBLIN-Direct
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Q
The document you just reviewed which had
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the warning labels from '83 to *87 and *87 to present,
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do you know where this document was generated from?
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A
NO.
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Q
Do you have any idea how it appeared in
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this packet?
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A
No, I didn't even see it until just now.
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Q
This is the first time you have seen this
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document?
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A
Yes.
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Q
Do you have any idea if it was provided by
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Hr. Maples?
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A
If I just saw it for the first time, 1 wouldn't
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have any idea how it got there. Probably it got there
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by Hr. Maples but 1 don't kno.w.
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Q
Did there come a time in your position
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with Chrysler that there was an awareness that exposure
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to asbestos dust generated by asbestos brake linings
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could cause cancer?
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A
1 don't know how I can answer that question. X
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would have to ask every employee of Chrysler whether
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they have any knowledge like that.
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Q
Are you aware of any knowledge like that?
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A
NO.
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Q
Do you have any idea why that warning
Brody a Geiser (201) 738-8555 or <212) 732-0644
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would be placed on an asbestos-containing product by
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Chrysler?
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HR. KONDLA: You are talking about which
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warning?
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Q
From *87 to present.
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A
Because somebody probably felt it was prudent to
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do so. To protect Chrysler, not admitting there is,
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but simply to protect Chrysler.
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Q
To protect Chrysler from what?
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A
From lawsuits and have a defense in lawsuits,
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and if Chrysler was wrong, that Chrysler would want --
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and if there is a danger, Chrysler wanted to warn
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people who are its customers that that danger might
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exist.
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Q
Do you have any information that leads you
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to believe that Chrysler might be wrong?
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A
NO.
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HR* COLEMAN: I'm not sure -- wrong about
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what?
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HR. C1FALDI: What he just referred to.
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Do you want it on or off the record?
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HR. COLEMAN: Off the record is fine. I'm
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not sure --
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MR. C1FALDZ: Off the record.
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(Discussion off record.)
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Q
In the memo dated 11/1/83/ which is page 2
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of p-Chrysler-2, there's a discussion of part numbers
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in the high risk category of brake components/ clutch
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facings/ et cetera. Do you know what the high risk
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category means?
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A
NO.
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Q
When you got this memo, did you become the
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least bit curious what the high risk category meant?
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A
No.
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Q
When you read this memo, did you do
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anything?
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A
1 don't know what you mean, did I do anything.
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Q
As a result of receiving this memo, did
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you do anything?
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A
You have to let me see the exhibit.
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Q
Sure.
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A
I noted they took my suggestion and instituted a
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warning and wrote back saying, thanks, I'm glad you did
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it and I recommend you change the service manual
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warning.
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Q
I guess we would have to ask Nr. Anderson
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what he meant by high risk category. Is that correct?
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A
That's correct.
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Q
Just so I'm clear, what exactly were the
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warnings placed on?
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The box that the replacement brake linings are
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sent in or packaged in.
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Q
in addition to the box, were warnings
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placed anywhere else?
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A
Not to my knowledge.
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Q
were warnings put in service manuals?
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A
when?
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Q
Good question. Were they ever?
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A
Yes.
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Q
When?
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A
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1973. MS. D'ANNUNZIO:
*73?
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THE WITNESS: '73.
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q
Do you recall what the nature of the
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warning was in the service manual in 1973?
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A
we just read ittogether.
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Q
So the warning that appeared in the 1984
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manual was identical to the warning-that appeared in
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the 1973 manual?
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A
Z don't know what you are talking about. What
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you showed me I thought was the 1973 manual. That's
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the only warning I'm aware of that was ever put in the
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service manual.
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q
I'm a little confused here. What do you
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base your belief on that this was the 1973 service
B t d d r t C*'144f 12U1F 73B-B55S or <212* IV 1 -W U
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manual?
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A
Because the only service manual 1 have ever seen
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that had a warning in it was a 1973 service manual.
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I`m assuming this is that warning. If that's a 1984
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service manual* then I haven't seen it before.
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q
To the best of your belief* there was a
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warning in the 197 3 service manual?
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A
Yes.
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q
h o w did you first become aware of that
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warning in the 1973 service manual?
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A
Because I went through all the service manuals I
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could find.
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q
why did you go through all the service
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manuals you could find* Mr. Koblin?
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A
To see if we ever made any warnings.
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q
Was that in conjunction with some other
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litigation?
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A
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Ves.
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Where does Chrysler keep the service
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manuals you reviewed?
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A
I'm not sure because they are kept now by an
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outside company somewhere.
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q
d o you know who the company is?
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A
No.
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q
Do you know who would know that?
Brody & Geiser (201> 738-8555 or (212) 732-0644
KQBLIN-Direct
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A
Some of the product liability people would know
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that.
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Q
Can you give me a name?
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A
Kenneth Gluckman.
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Q
When did you make your review of the
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service manuals?
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A
Sometime after 1978.
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q
Do you possess copies of the sections you
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deemed relevant to the asbestos litigation?
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A
Mo, the only part that was relevant to asbestos
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litigation was that part we just talked about.
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Q
Based on your review of those service
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manuals, would it be a correct statement that that
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warning appeared in every service manual after 1973?
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A
Mo, that would be incorrect.
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Q
What would be a correct statement?
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A
It appeared in the 1973 service manual.
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Q
The service manuals after 1973 that you
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reviewed did not contain that warning?
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A
That is right.
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To your knowledge did that warning ever
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appear after 1973?
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A
Mo.
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MR. CIFALDI: At this time I would like to
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request the service manuals from Chrysler
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Corporation from 1960 forward# and most
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specifically I would like to request the service
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manual which has been referred to here today.
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Q
Other than the service manual I showed
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you# there's an indication "1984 front wheel drive
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service manual" written on the top. Do you have any
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idea who wrote that or where that came from?
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A
NO.
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Q
Do you have anything that would lead you
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to believe that that information was indeed contained
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in the 1984 servicemanual?
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A
No.
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Q
Now that we are back in 1973# do you have
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any idea why a warning was put in the service manual?
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A
NO.
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Q
Do you know who would have an idea about
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that?
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A
No. a s amatter of fact# 1 tried to find out
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and couldn't.
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Q
Thank you for volunteering that
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information.
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HR. CXFALDX: At this time I would like to
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request that Chrysler supply me with the name of
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the individual or individuals that are
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knowledgeable as to the warning that was placed
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in the service manual in 1973, and certainly x
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believe that was encompassed by my Deposition
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Notice.
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HR. KUNDLA: The fact somebody already
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tried to locate that person and has been
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unsuccessful, that's probably an indication of
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what the future response to that request will
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be.
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HR. CXFALDIs No offense intended but
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certainly l have a right to inquire as to the
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basis of that response.
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HR. KUNDLA* 1 fully understand that.
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Q
1 bet you couldn't find the person
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responsible for removing that from the service manual
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either, right?
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A
That is right.
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Q
Based on your review of the service
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manuals, was there any indication in the manual in the
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front somewhere as to who was responsible for the
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preparation of the manual?
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A
No, 1 don't remember,
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Q
Do you Know if Chrysler prints those
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manuals in-house or they send them out?
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A
Probably send them out.
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Q
if I was a person that worked in some area
Brody 6 Geiser (201) 738-8555 or (212) 732-0644
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that used Chrysler products and X got a service manual
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in 1973 and it bad this warning in it and I had some
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questioner who would X call?
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MR. KUNDLA: Objection to the form. You
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can answer if know.
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A
Depends on what questions you have, x can't
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answer that.
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Q
Say I had a question about the warning.
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A
X don't know. I don't know who you would call.
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Q
Is there any department that handles
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questions on service manuals at Chrysler?
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A
X don't know.
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Q
Who would have that type of information?
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A
I don't know.
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Q
Any department?
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A
Might be.
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Q
Is there a customer information
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department?
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A
X don't know. There might be.
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Q
is there any type of document that
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Chrysler has that maybe sets forth the particular
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departments involved with the corporation and their
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function?
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A
No, not that X have everseen.
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MR. CIFALDI: At this time X would like to
Brody a Geiser (20li >38-0555 or (212) 732-0644....