Document aJxmdv8j6pxdGww7qzVyBwMja

SEP. 13.2004 2:57PM RWDM LAW FIRM Multi-PageTM NO. 653 P. 3 Appearance o: Fot tbe Qofc&danc E&ctaso-Xbcx'. SMITH X&BOt, X&sfte vv toot Plata Bov sta, rev iooe BXI 1. KMWD f. ABBOT roc chc Oefendanb Genuine Etrei Ceeunayi rxiwr* Hem, hbmjtt < bvzxtzzr. 660 Washingcon Hoad Suite 900 Plctsboroh, Peafijylveoi* 15229 Vti MS. `PATRICK R. RZLSV RjLSKO&g?C, HIXXZB, OZCICY c tooos, L.L.C. 9200 Marti Parkway Suite 910 Kiuutts city, Missouri (ills bxi kr, eucrror b. picket IIDEX ODlKLBS RUUM M.LCH VMt fixonliMeloa by Mr. duierla............................................ ExtttL&etiea by ftl Abbot............................................................. 10 ftxAaiAAtloa by Mr. Alley..................... ............................... 21 EmaImcIqa by Mb. Abbot..;.........T,..,........................ 21 Eqggdaatlou by Mr. Cloned*................. >............................ 19 QSPOeZTXON nSXBXT VO. (MOKE) EXHIBITS HflO % 1 of 1966 wborc I wmt to Genaut Industries jn 2 StepbenviHc, Texas, and went to week. It was a 3 wholly-owned subsidiary of Gap or Genuine ' 4 Automotive Parts, and fromihere I went to 5 Morganfidd in 1974. and I'm'thac until today. 6 Q.Olcay, When yon went to Morganficld in. *74, 'woe you 7 wodang for Rayioc? 8 A.No, it was still Genaut Industries. 9 Q.Okay, trad when did your employee change from Gcnai 10 Industries? 11 A. 1984. 12 Q.Who did you go to wodc for in '847 13 ARayloc. 14 Q.You'vc worked for Rayioc ever since7 15 A. Yes. 9 16 Q.Okay. Cm you explain let's go back to Genaut 17 ' Industries in 1966. Can yon explain die 18 iclstioashrp, ifany, to KAfAt 19 A. They supplied the KAPa distribution centers 20 throughout most of the central United States with 21 the exception of Oklahoma City and they also had a 22 branch at Tulsa, aod they also had the Standard 23 Unh pans upia Chicago, Normal and Sank Village I 24 think h was a part of** it was not part of Oat, ' 25 but we had the rest of it through die central all CHARLES WILLIAM ALLEN, of lawful age, after having been first duly sworn to tell the truth, the whole truth, and nothing but the truth, testified as follows: EXAMINATION . BY MR. GlANARIS: - 7 Q.Sir, please state your name. 8 A. Charles William Allen. 9 Q. Charles William Allen? 10 A.Yes, A-L-L-E-N. 11 Q.Where do you live, Mr. Allen? 1 the way out into Des Moines and Dcwirt and Kansas 2 City. 3 Q.So, for a certain section of the country, Genaut 4 was a. supplier for NAPA3 5 AYes. 6 Q.Supplier of auto parts? 7 AYes, icn^irfaiaaredautopartE. 8 Q.Including brake linings? 9 A.Yes. 10 Q.What was your job -- go through your job starting 11 in '66 to the present. 12 Al live in Moiganfield, Kentucky. 13 Q.Can you give us your address, please? 12 AI was a foreman in the plant. 13 Q.Okay. 14 A 206 Valley Drive. 15 Q.What's youx date of birth? 16 A 9-17-39. 17 Q.Okay, are yon a married man? 18 AYes. 19 Q.Where do you work? 20 Al work far Rayioc in Morganfidd, Kentucky. 21 Q.Can you just -- let's rewind and go back to when 22 you got out of high school, let1 s say. Give me 14 A. And I moved hum that to a plant manager, and, 15 then, when I went to Morganfield, I was the plant 16 manager thae, then, in '84 when the buyout came, I 17 went to general manager. 18 Q.Okay. And yoqlre still general manager? 19 AYes. 20 Q.It's siy understanding that Genaut had, for lack o 21 a better term and maybe it's the proper term, 22 competitors or a couple of competitors fbronghmi 23 your work history, if you would. 24 Al went to-work at Metro Electric Company in 25 approximately 1959. I worked there until mid year 23 the country who also supplied najpa is that 24 correct? 25 aWell, Genuine Parts would be one. JOHN M. BOWEN & ASSOCIATES - (81$) 421-2876 Page 2 -P