Document X3x5w04q2M3moJdybYNeGO84
Marcella Duncan 7-22-04.txt
9 MR. PARKER: NO. BECAUSE SHE UNDERSTANDS THERE
10 IS A DIFFERENCE. IF YOU WANT TO DEFINE TERMS, THAT'S A
11 BETTER IDEA. WHY DON'T YOU DO IT IN A WAY SHE CAN
12 UNDERSTAND?
13 THERE IS NO QUESTION.
14 BY MR. FISHBACK:
15 Q. YOU WORK FORDANACORPORATION;CORRECT?
16 A. CORRECT.
17 Q. HAVE YOU EVERWORKED FOR VICTOR GASKET COMPANY?
18 A. NO.
19 Q. WHAT IS YOUR UNDERSTANDING OF THE RELATIONSHIP
20 BETWEEN THE TWO?
21 A. DANA CORPORATION IS THE CORPORATION MADE UP OF
22 MULTIPLE DIVISIONS OF WHICH THE SEALING PRODUCTS
23 DIVISION, FORMERLY VICTOR REINZE, FORMERLY VICTOR
24 PRODUCTS DIVISION, IS ONE OF THOSE DIVISIONS. DANA
25 CORPORATION IS PEOPLE, NOT PRODUCTS. PRODUCTS ARE MADE AT
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1 THE DIVISIONS.
2 Q. ALL RIGHT. SO DANA CORPORATION NEVER
3 MANUFACTURED A GASKET?
4 A. THAT'S CORRECT.
5 Q. IT HAD DIVISIONS THATMANUFACTURED GASKETS?
6 A. THAT'S CORRECT.
7 Q. ALL RIGHT. DANA CORPORATION DOESN'T
8 MANUFACTURE ANYTHING, DOES IT?
9 A. CORRECT.
10 Q. BUT THERE ARE EMPLOYEES OF DANA CORPORATION?
11 A. YES.
12 Q. AND ARE THERE SIMPLY EMPLOYEES OF VICTOR
13 CORPORATION OR VICTOR COMPANY, THE VARIOUS DIVISIONS?
14
MR. PARKER:
WAIT. THAT'S THREE QUESTIONS.
15 WHICH ONE DO YOU WANT HER TO ANSWER? OTHER EMPLOYEES OF
16 THE DIVISIONS?
17 MR. FISHBACK: YES.
18 MR. PARKER: DO YOU UNDERSTAND THAT?
19
THE WITNESS:
YES. AND WE ALL WORK FOR DANA
20 CORPORATION.
21 BY MR. FISHBACK:
22 Q. WHEN YOU STARTED IN 1968, YOU WERE EMPLOYED BY
23 DANA CORPORATION?
24 A. DANA CORPORATION AND THE SERVICE PARTS DIVISION.
25 Q. OF DANA CORPORATION?
0059
1 A. DANA CORPORATION.
2 Q. WHEN YOU GOT YOUR PAYCHECK, DID IT SAY "DANA
3 CORPORATION" ON IT?
4 A. PROBABLY.
5 MR. PARKER: IF YOU --
6 THE WITNESS: YES, WITH SEALING -- WITH THE
7 DIVISION NAME.
8 BY MR. FISHBACK:
9 Q. ALL RIGHT. WHEN YOU GET YOUR PAYCHECK TODAY,
10 DOES IT SAY DUST "DANA CORPORATION" ON IT?
11 A. NO.
12 Q. IT INCLUDES THE DIVISION AS WELL?
13 A. YES. BUT I DON'T GET A PAYCHECK. IT'S
14 AUTOMATIC DEPOSIT.
15 Q. OKAY. YOU GET PAID, DON'T YOU? 16 A. YES.
17 Q. INCIDENTALLY, ON THE ISSUE OF PAYMENT, YOUR 18 FULL-TIME JOB ISN'T OBVIOUSLY TO BE A WITNESS, AS YOU
19 ALREADY INDICATED, BUT YOU'RE GETTING PAID TODAY BY DANA
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