Document VJeXnNn9Gzq6KJ1xpZKvX9Y8o

ROGER HOBBIE Page 70 Page 72 1 A It appears that the purchasing -- well, the 1 A Yes. 2 principal buyer for the Eaton axle brake division wrote to -- 2 Q What is it? 3 1 think Mr. Jim Pruneski's title was the president of Abex at 3 A It's a letter to Freightliner, I believe purchasing. 4 the time and alerting him to the situation where the lack of 4 Q What is the date of the letter? 5 availability ofthe nonasbestos for the high friction 5 A The date ofdie letter is October 15, 1986. 6 applications which would be more of a heavy duty nonhighway 6 Q Who is it addressed to? 7 type dump trucks, things like that, those applications. 7 A Mr. Michael Harmon,Freightliner Corporation, 8 And basically, he was telling them that Eaton 8 Portland, Oregon. 9 was in a position that they couldn't supply product with the 9 Q Who is it from? 10 nonasbestos lining at that time and of course the asbestos 10 A Larry Hopper, Eaton axle and brake division, OEM 11 material was evidently no longer being supplied either. 11 account manager for Eaton to Freightliner. 12 Q The person who wrote the letter, what is his name? 12 Q At the bottom, there is a cc. list? 13 A Thomas Bruggeman. 13 A Yes. 14 Q Did you know Mr. Bruggeman? 14 Q Do you recognize any of the names on the cc. list? 15 A I knew who he was but never had any direct business 15 A A few of them. 16 dealings with him. 16 Q Could you name them and describe who they are? 17 Q Do you recognize any of the c.c. names copied in on 17 A R. Young was Robert Young. He was the axle brake, 18 this correspondence? 18 Eaton axle brake division, OEM sales manager. Tom Furdek was 19 A Yes. 19 an Eaton axle brake engineer. Jim Clark was the chief 2 0 Q Who do you recognize? 20 engineer of die brake product. Jim Tipka was an engineer for 21 AG. Cotter, George Cotter, at the time he was general 21 Freightliner in Charlotte, North Carolina. Ron Salter I don't 22 manager of the axle brake division. Williams Hoenes was 22 know. Rainier Kaiser worked for Freightliner. JohnBohm, 2 3 engineering manager ofthe axle brake division. Bob llle I 23 B-O-H-M, was an engineer for Freighdiner. Curt Doane 1 don't 2 4 think was purchasing manager at that time. Gopel Singh, I 2 4 know. Beck Baxter, Portland Freightliner employee, I don't 2 5 think he was actually the chief - chief brake engineer at the 2 5 know. D. Welker, I don't know. Denise Reeves, I don't know. Page 71 Page 73 1 time. Jim Clark worked for him. He was titled chiefhighway 2 brake engineer. John Lilly was in Gallatin. 1 think he was 3 sort ofthe in-house sales guy at the Gallatin plant for brake 4 product. 5 Q The high friction concerns dial were being raised in 6 tliis letter, is it just related to these off-road vehicles you 7 are talking about or were there other on-road vehicles that 8 would fall into that high friction catcgoiy? 9 MR. HAFNER: Can you speak up a little bit? 10 It is hard to understand what you are-saying. 11 A They could have been in some on-road applications 12 like, say, refuse trucks, mixer trucks, but primarily more 13 off-road heavy-duty applications. They wouldn't have been 14 used in a general over the rand highway type hauling 15 application. 16 MIL HAFNER: Is there a date for that exhibit? 17 MR. BARTELS: October 15,1986. October 14, 18 1986 is Hobbie 14, a letter to Mr. J. Pruneski, Abex 19 Corporation, 3001 West Beaver Road, Troy, Michigan from Thomas 2 0 Bruggeman, principal buyer of Eaton. 21 Q I will show this to I-larry. 22 (Exhibit 15, letter-10/15/86, was marked Tor 23 identification.) 24 A Okay. 25 Q Have you had a chance to look at that exhibit? 1 Jay Cowan, I don't know. 2 Q What is your understanding ofwhat the letter was 3 for? 4 A It appears to me they were proposing to Freightliner 5 that because ofthe lack of availability of the approved high 6 friction nonasbestos lining, there were some idea or a concept 7 that they could look at specific applications and maybe be 8 able to fine-tune by making other adjustments to the brake 9 system where they could use the medium friction nonasbestos 10 instead of having to go to asbestos and that would be by maybe 11 using a larger air chamber size or a longer slack adjuster to 12 be able to meet the stopping requirements of that particular 13 vehicle or number of vehicles. So it was sort of a way they 14 could try to fine-tune the system to get by this lack of a 15 high friction. 16 Q On the first page, the writer mentions stockpiles. 17 Do you see that? IB A Yes. 19 Q Do you know what he is referring to with respect to 2 0 this mention of stockpiles? 21 MR. QUICK: Objection. You can answer if you 22 know. 23 A I guess T would have to assume that purchasing had 2 4 increased their normal stocking quantities and had some higher 2 5 levels of stock available to get through this interim period. 19 (Pages 70 to 73) (800) MERRILL LEGAL SOLUTIONS 325-3376 www.MerrillCorp.com 5cfe6bcd-afe7-469e-b187-b081 ecda30a3