Document YGrLqeBOQYLYO4r3qmzZMEKDD

Marcella Duncan 7-22-04.txt 18 AN O.E. SERVICE LOCATION, A RAW MATERIAL CUSTOMER. 19 SO WHEN I GET A SALES REPORT, I GET A REPORT OF 20 ALL MY CUSTOMERS BROKEN DOWN BY -- THESE ARE ALL MY 21 O.E.M. CUSTOMERS, THESE ARE ALL MY O.E. SERVICE 22 CUSTOMERS; AND THEN I -- I ALSO GET THE SAME TYPES OF 23 REPORTS FOR THE OTHER ACCOUNT MANAGERS AND GIVE THEM 24 THEIRS. 25 Q. IS THE INFORMATION CONTAINED IN THOSE REPORTS 0283 1 INCLUDED IN THE TIME PERIOD OF 1959 TO 1980? 2 A. NO. 3 Q. WHEN DOES THE INFORMATION BEGIN, THE EARLIEST 4 DATE? 5 A. 1988 -- NO. JANUARY 1ST, 1989. 6 Q. WHAT DOES BORGWARNER PURCHASE FROM VICTOR DANA? 7 MR. SABNIS: THIS IS ROHIT SABNIS. LACKS 8 FOUNDATION AND CALLS FOR SPECULATION. 9 MR. PARKER: THIS IS RELATED TO VICTOR 10 GASKETS. THE TOPIC IS VICTOR GASKETS AS SOLD TO 11 BORGWARNER. YOU CAN ASK ABOUT THAT, NOT ALL PRODUCTS. 12 BY MR. FISHBACK: 13 Q. OKAY. DOES BORGWARNER PURCHASE GASKETS FROM 14 VICTOR DANA? 15 A. YES. 16 MR. SABNIS: SAME OBJECTIONS. SABNIS. 17 BY MR. FISHBACK: 18 Q. HOW LONG HAVE THEY BEEN A CUSTOMER? 19 A. I DON'T KNOW HOW LONG. THEY'RE ONE OF MY 20 ACCOUNTS. ANOTHER ONE OF MY ACCOUNTS ACTUALLY. 21 Q. DID YOU INHERIT THE ACCOUNT WHEN YOU BECAME A 22 PART OF THE SALES DEPARTMENT? 23 A. YES. 24 Q. SO YOU HAVE NO ESTIMATION OF HOW LONG THEY'VE 25 BEEN A CUSTOMER OF DANA? 0284 1 A. NO. 2 Q. DO YOU HAVE ANY SPECIFIC INFORMATION ABOUT 3 MAREMONT CORPORATION OTHER THAN THE NAME SOUNDS FAMILIAR? 4 A. THAT'S IT. I'D HAVE TO RESEARCH THAT ONE. 5 Q. WHAT INFORMATION DO YOU HAVE ABOUT PARKER 6 HANNIFIN CORPORATION? 7 A. THEY'RE ANOTHER ONE OF MY MISCELLANEOUS 8 ACCOUNTS. THEY'VE BEEN A CUSTOMER FOR MANY YEARS. THEY 9 BUY SOME GASKETS FROM US. 10 Q. HAVE YOU SPOKEN WITH ANYONE IN THE COMPANY 11 ABOUT THE SUPPLY OF GASKETS TO ANY OF THE OTHER COMPANIES 12 LISTED IN EXHIBIT B? 13 MR. PARKER: AT ANY TIME HAS SHE SPOKEN TO 14 ANYBODY? 15 MR. FISHBACK: YES. 16 MR. SABNIS: OVERBROAD; COMPOUND. SABNIS. 17 MR. PARKER: IT'S A YES OR NO, AND HE WILL ASK 18 FOR FOLLOW-UP IF HE WANTS TO. 19 THE WITNESS: EVER IN MY WHOLE LIFE? 20 BY MR. FISHBACK: 21 Q. YES. 22 A. YES. 23 Q. WHO ELSE OTHER THAN THE COMPANIES THAT YOU'VE 24 LISTED, WHAT OTHER COMPANIES HAVE YOU DISCUSSED ON 25 EXHIBIT B? 0285 1 MR. PARKER: I'LL OBJECT. CAN YOU REPHRASE 2 IT? MAYBE I MISSED IT. Page 118