Document RJ6Z10zykvvrXQjKyN0GDbEOV

SEP. 13.2004 2:58PM RWDM LAW FIRM Multi-PageTM NO. 653 P.4 \ Page 6 Pago 8 Q.Okay. Who is the other one? 1 asking me did I know anything about it, and I 2 a. Standard Units would be one. 2 really didn't, I had never messed with' one of those 3 Q.Any others? 3 before, it was an arcing grinder, high speed 4 A.I would say Oklahoma City would be one, that's 4 grinder; and Td sayjust in talking with people, 5 Brittain Brothers. 5 as far as 1 remember, a gay by the name of John 6 MR. ABBOT: Brittain? 6 Banks who was in Indianapolis -- I'm sorry, 7 THE WITNESS: Brittain Brothers. 7 Evansville, Indiana, at the rime, he came, down and 8 MR. RILEY: B-R-I-T'T-A-I-N. 8 they always introducing me to all these folks. 9 A. Brittain Brothers.' 9 old-timers, and they were always oiling me about 10 MR. RILEY: And he's talking historical. 11 not current 10 our relationship with die Napajobbers and American 11 Brakebloc, who I call Abex, andjust the way of 12 MR chanaris: Okay, right 12 conversation, I guess my teaching and training. 13 Q.(BfYMR. (SaNakis) Okay, well, let's talk about 13 Q.So your teaching, training, and conversations with 14 that How far back -- how far back does your 14 people employed or affiliated with NAPA is what 13 historical knowledge of Genant's relationship to 15 you're basing your historical knowledge on? 16 NAPA go? 16 A When I was talking about die '30's, because my 17 A.Well, Genaut was part of - they were a 17 knowledge with NAPA started in 196$. 18 wholly-owned subsidiary of Genuine Automotive 18 Q.RJght So, prior to -- what you know about it 19 Parts, but there was also another company BHT 19 prior to 1966 comes from those -- 20 Products in Indianapolis that was also a 20 A That's correct 21 wholly-owned subsidiary, and we woo just like a. 21 Q. -- those sources I just mentioned? 22 sister. In fact, our plant manager die reason I 22 a.Yes, that's right 23 became plant manager was because he was promoted to 23 Q.Okay. So, going back historically before you 24 general manager of the two plants, and we both 24 started in 1966 all the way let's say through die 2* supplied Gap and all the Napa stores that were 25 1970's to the end of the 1970's, Was Abex or Page 7 Page 9 1 supplied by GAP of remanufacrnred product, and the 1 American Brakebloc a supplier of friction 2 BUT plant went all the way back into the '30's. 2 materials, brake friction materials, to napa? 3 Q.Okay. Do you know hcrw far back the other I'll call 3 A. Yes. 4 them competitors, because that's how we termed it 4 Q.Okay. Now, if a person went in a napa store to buy 5 earlier, competitors supplied NAPA? 5 brakes tmd they bought brakes, they came in a napa 6 A. To my knowledge, and this is just tabring.to-Walter 6 box with a napa label on them, would those brakes 7 Devoe, who is die plant manager there at 7 during that period of time have been supplied oar 8 Stephenville, and all the old - when we was 8 those friction parts in that box have been, supplied 9 starting the new plant, we had a lot of old-timers 9 by Abex or American Brakebloc? 10 come in, see the new facility, and they was always 10 A.This is from '60 through the '70's or further back? 11 trying to teach me about napa because I really knew 11 Q.Let's go back to your historical knowledge, what 12 nothing about Napa at the time, and ibis goes -- 12 you know, as far back as yon know. 13 they go all the way back into I'm sure Genuine 13 A. I'd say It goes all the way back somewhere in the 14 Parts and all of diem all the way back in die 14 '30's. 15 '30's, also. Everything was Abex at that time. 15 Q. Okay. And that would be the situation throughout 16 Q.Let me ask you about that. Yon say everything was 16 . the country including the parts your company 17 Abex? 17 supplied and your competitors supplied to napa? 18 A.Yes. 18 A.Yes. , 19 Q.Eiplain that to me. 19 Q.Okay. 20 A.Wdl, in all of our meetings, in fka, the day I 21 went to work at Stephenville, the American 22 Brakebloc representative was there, they were back 23 there him and Walter trying to set up a production 2* grinder to grind brake shoes, and this was a ; gentleman named Dale Schoonover, and they were 20 MR. GIANAR1& l&ink that's 8ll I have 21 for now. 22 MR abbot-. Let's take just a break for a ; 23 second. 24 (BRIEF RECESS TAKEN.) 25 Q. (by mil GtANAKis) Sir, American Brakebloc and 6 -Page 9 JOHN M. BOWEN & ASSOCIATES - (816) 421-2876