Document Y4k7VVJjYMQVjpza3jKLmQJn

Hicks, et al. v. ACandS, Inc., et al. . 6/1/01 Paul L. LeCour Page 154 Page 156 1 Parts, have you gone out to the field to see whether or. 2 not mechanics were in fact grinding your brake shoes? 3 A. Oh, yes. 4 ,Q. When have you done that? 5 A. 1 did that from 1971 through '75. And 1 did 6 it periodically, not specifically just to go see if 7 they're grinding or not, but going in and calling on 8 garages that do brake workup, until this year. 9 Q. From 1971 through 1975, what were you doing 10 that required you to see whether or not your products II ' were being ground? 12 A. I was conducting the brake clinics and the .13 dutch clinics and the electrical clinics. And 1 was. . 14 also selling the product to our jobber customers. 15 We would go along with the jobber salesman and ' 16 tell him why should you buy Rayloc and not Raybestos. 17 Q. I've seen Ihe documents of a slide 18 presentation. Were you involved in that slide 19 presentation? 20 A. Well, there were several series of that. 21 But, yes, 1 had a slide presentation that I used. 22 Q. When did you prepare those slide 23 presentations? 24 A. That was given to me when 1 came to work for .25 the company. i My question is: Was one of your angles, in an 2 effort io sell Rayloc, that you told garage mechanics 3 that you do not have to grind our shoes?. 4 A. Yes. 5 Q. At any time, did you tell them any of the 6 . dangers associated with actually grinding shoes related. 7 to creating asbestos dust 8 A. No..' 9 Q. ~ now, other than 1971 to '74,1 think you 10 said? 11 A. '71 to '75. 12 Q. '75, what else were you doing to actually go IJ to particulargarages? fust go on sales calls? 14 MR. RILEY: Time period? 15 MR: SMITH: When? 16 Q. (By Mr. Dumler) After 1975? 17 A. No. IS MR. RILEY: No. He said 71 to 75. 19 Q. (By Mr. Dumler) No. 1 said other than 71 . 20 to 75. After '75; what else were you doing to go visit 21 specific .mechanics? 22 A. 1 would be going fur problem calls where they 23 were having a problem with our product, not just 24 specific brake product, but any product. We had 25 19 product lines. . Page 155 Page 157 , 1 Q. So you would go out to various garages and 2 give them presentations about how or why they should use 3 your particular products? 4 A. Yes.. 3 Q. During the course of any of those 6 presentations, did you warn any or advise any mechanics 7 about the dangers associated with asbestos dust from 8 grinding? 9 '* A. No, I did not. 10 Q. In any of those slide presentations, was there II ever any indication or warning about the dangers 12 . associated with creating asbestos dust? 13 A. No, there was not. 14 Q. In connection with selling Raybestos products. 15 one of your angles was that you did not have to grind 16 your brake shoes or pads; is that correct? 17 . A. No. Yuu said Raybestos, 18 Q. I'm sorry. Rayloc. 19 A. And 1 would inject this: that that is the 20 mein problem but there, a tot of people -- Ro/beitoj 21 king in JcJHu** brake shots. And a lot of people 22 though! we, Huyloc, were Raybestos. So when you ask 23' them, whose brakes did you use. wc used the Rayloc; but 24 actually it was Raybestos. 25 Q. Thank you. . 1 Q. How often would you do that? 2 A. Maybe a dozen times a year. 3 . Q. In those Instances in which you attempted to 4 distinguish your product from other products that needed 5 to be ground, who were the competitors that you singled' 6 out as companies producing products that you had to 7 grind? 8 A. We always used the practice that you never 9 knock vour competition.-So we never talked about our 10 competition, we only talked about the benefits of our II products. 12 Q. One of the benefits, you testified, was that 13 you didn't have to grind your product? 14 A. That's correct. 15 Q. What would you do in comparing your product to 16 other products? Would you say the other products you 17 have to grind? 18 . A. Nil. \S'e would just say that you don't have to 19 do anything to modify our shoes to install them. 20 Q. Did you ever visit Mr. Novo's $a$ stations in 21 New jersey? 22 A. No, 1 did not. 23 Q. Did you ever visit any of the jobbers in 24 New Jersey? 25 A. 1 cannm recall. . 40 (Pages 154 to 157) . WHEELER REPORTING'COMPANY, fNC., 404-351-4577