Document YGOBwmRNnBkVDa3YYGxrRdzaK

SEP. 13.2004 2:58PM RWDM LAW FIRM Multi-Page NO. 653 P. 4 "\ 1 Page 6 Page 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 ooe. 2 really didn't, I had never messed with one of those 3 Q.Any others? 3 before, it was an arcing grinder, high {peed 4 A.I would say Oklnhocia City would be one, that's 4 grinder, and Pd sayjust in talking with people, 5 Brittain Brothers. 5 as far as I remember, a guy by the name of John 6 MR. ABBOT: Brittain? 6 Franks 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-f-T-T-A-I-N. 8 they always introducing me to all thes* folks. 9 A-Brittain Brothers.' 9 old-timers, and they were always telling me about 10 MR. RILEY.- And he's talking historical, 10 our relationship with the napAjobbers and American u not current 11 Brakebloc, who I call Abex, and just the way of 12 MR. GIANARIS: Okay, right 12 conversation, I guess my teaching and training. 13 Q.(BYMK GIaNajrjs) 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 15 historical knowledge of Genaot's relationship to 15 you're basing your historical knowledge on? 16 NAPA go? 16 a. When I was talking about the '30's, because my 17 A. Well, Genaut was part of - they were a 17 knowledge with Napa started in 1966. 18 wholly-owned subsidiary of Genuine Automotive 18 Q.Right 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 AThat's correct. 21 wholly-owned subsidiary, and we woe just like a 21 Q.-- those sources I justmentioned? 22 sister. In fact, our plant manager the reason I 22 A.Yes.thar'srighL 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 the supplied Gap and all the napa stores that were 25 1970's to the end of the 1970'$, Was Abex or ; Page 7 Page 9 1 supplied by GAJP of ^manufactured product, and the 1 American Brakebloc a supplier of friction 2 BHT plant went all the way back into the'30's. 2 materials, brake friction materials, to napa? 3 Q.Gfcsy. Do you know how far back die 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 and. they bought brakes, they came in a NAPA 6 A. To my knowledge, and this is just talloag.to'Walter 6 box with a NAPA label on them, would those brakes 7 Dervoe, who is die plant manager there at 7 during that period of time have been supplied or 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 die '70's or further back? 11 trying to teach me about napa because 1 really knew 11 Q.Let's go back to your historical knowledge, what 12 nothing about Napa at (he rime, and this goes -- 12 you know, as far back as you 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 die wry 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. Explain that to me. 19 Q.Okay. 20 A.WeU, in afl of our meetings, in fact, the day I 20 MR. GIANARIS; I think that's all I have * 21 went to work at Stephenville, the American 21 for now. 22 Brakebloc representative was there* they were back 22 MR. abbot: Let's take just a break for a ; 23 there him and Waller ttying to set up a production 23 second. 2* grinder to grind brake shoes, and this was a 24 (BRIEF RECESS TAKEN.) , gentleman named Dale Schoonover, and they were . 25 Q. (by MR. GLANARtS) Sir, American Brakebloc and ge 6-Page 9 JOHN M. BOWEN & ASSOCIATES - (816) 421-2876