Document V8ZXpO73wm94VN88rbR5ZyNq

Marcella Duncan 7-22-04.txt 16 MR. PARKER: NO. NO. LET HER ANSWER. 17 BY MR. FISHBACK: 18 Q. EXHIBIT A, JUST TO BE CLEAR, IS THE LIST OF 19 THOSE COMPANIES, FORD MOTOR COMPANY? 20 A. AT THE TOP HERE, YES, RIGHT. I SEE THAT. 21 "ALL INFORMATION REGARDING YOUR SUPPLY OF 22 VICTOR GASKETS TO ANY PERSON LISTED ON EXHIBIT A, 23 ATTACHED HERETO, AT ANY TIME BETWEEN JANUARY 1ST, 1959 24 AND DECEMBER 31ST, 1980, FOR INCORPORATION AS ORIGINAL 25 EQUIPMENT, (COMMONLY KNOWN AS O.E.M.) COMPONENT PARTS." 0254 1 I HAVE NOTHING PREPARED OR RESEARCHED TO 2 RESPOND TO THAT. 3 Q. SO IT'S SOMETHING THAT YOU COULD POTENTIALLY 4 RESPOND TO, IF YOU WERE GIVEN ADEQUATE NOTICE AND YOU 5 COULD GO LOOK AT RECORDS OR CONSULT WITH OTHER FOLKS, 6 BUT AS YOU SIT HERE NOW, IT'S NOT SOMETHING YOU'RE 7 PREPARED TO TALK ABOUT, OFF THE TOP OF YOUR HEAD? 8 MR. PARKER: I THINK THAT'S THE CONFUSION -- 9 MR. FISHBACK: HOLD ON. 10 MR. PARKER: THAT'S THE CONFUSION. AND AFTER 11 THAT, WE'LL TAKE A BREAK. 12 THE WITNESS: I'M GOING BY ALL INFORMATION 13 REGARDING OUR SUPPLY. 14 MR. PARKER: YEAH. 15 THE WITNESS: I HAVE NO INFORMATION PREPARED. 16 BY MR. FISHBACK: 17 Q. CORRECT. 18 A. SO, NO, I CAN'T GIVE YOU ANY INFORMATION. I 19 DON'T HAVE ANY. 20 Q. AND THAT WAS MY QUESTION, WAS YOU -- IT IS A 21 SUBJECT MATTER ON WHICH YOU COULD TESTIFY IF YOU WERE 22 ADEQUATELY PREPARED AND YOU HAD THE OPPORTUNITY TO REVIEW 23 DOCUMENTS OR TALK WITH PEOPLE OR DO WHATEVER YOU DO TO 24 GET PREPARED SO YOU COULD LEARN ABOUT THIS SUBJECT 25 MATTER; IS THAT RIGHT? 0255 1 MR. PARKER: I'M GOING TO TALK TO MY CLIENT AT 2 THIS POINT. 3 MR. FISHBACK: NOT WHILE THERE'S A QUESTION 4 PENDING. 5 MR. PARKER: YES. 6 MR. FISHBACK: NO. 7 MR. PARKER: I'VE ASKED THREE TIMES TO EXPLAIN 8 TO HER WHAT IS GOING ON, AND THE QUESTION CAN BE ANSWERED 9 WHEN WE COME BACK. 10 MR. FISHBACK: MY QUESTION IS PENDING, AND YOU 11 KNOW IT'S IMPROPER TO DO ANYTHING WHILE THERE'S A 12 QUESTION PENDING. 13 MR. PARKER: AND I'VE ASKED SEVERAL TIMES TO 14 GIVE HER A CHANCE TO GET ORIENTED. AND SO I APPRECIATE 15 THE CONCERN. I UNDERSTAND THAT. 16 MR. FISHBACK: IT ISN'T AS THOUGH THIS IS THE 17 FIRST TIME YOU'VE SEEN THIS DOCUMENT. 18 MR. PARKER: ME? 19 MR. FISHBACK: CORRECT. 20 MR. PARKER: I HELPED WRITE THIS DOCUMENT. 21 MR. FISHBACK: I DON'T KNOW ABOUT THAT, BUT -22 THAT'S RIGHT, YOU WROTE IT. SO THAT'S WHY I'M ASKING THE 23 QUESTION I'M ASKING. AND I WOULD LIKE TO ASK THE COURT 24 REPORTER TO REPEAT IT. 25 Q. DO YOU HAVE MY QUESTION IN MIND? 0256 Page 106