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Marcella Duncan 7-22-04.txt 20 MR. FISHBACK: I'M NOT ARGUING WITH HER. 21 MR. PARKER: YOU SAID IT MUST BE THE CASE THAT 22 THIS HAPPENED. 23 MR. FISHBACK: YES. 24 MR. PARKER: THAT'S AN ARGUMENT. 25 MR. FISHBACK: I'M NOT GOING TO ARGUE WITH 0186 1 YOU. 2 MR. PARKER: JUST ASK HER A QUESTION. 3 BY MR. FISHBACK: 4 Q. DO YOU HAVE MY QUESTION IN MIND, OR DO YOU WANT 5 ME TO RE-ASK IT? 6 A. TELL ME THE QUESTION AGAIN. 7 Q. THE FIRST QUESTION IS IS THERE SOME OTHER 8 LOCATION WHERE THE PART NUMBER IS REFERENCED WITH A 9 SPECIFIC APPLICATION? 10 A. YES AND NO. NOT -- I DON'T MEAN TO SOUND 11 AMBIGUOUS HERE. THE O.E.M. CUSTOMER -- CHEVROLET, G.M., 12 WHOEVER -- HAVE US MAKE A PART FOR THEM. THEY HAVE A 13 PART NUMBER THAT THEY REFERENCE IN THEIR SYSTEM -14 HOWEVER THEY DO IT. I DON'T KNOW -- THAT IT WOULD GO FOR 15 THIS SPECIFIC APPLICATION. 16 I HAVE A NUMBER. OKAY. IN SALES WE HAVE 17 CROSS-REFERENCE FILES, HIS NUMBER TO MY NUMBER. MY 18 PEOPLE DON'T NECESSARILY KNOW WHAT KIND OF GASKET IT IS 19 OR WHAT IT FITS. 20 I CAN GO TO THE ENGINEERING FOLDER FROM MY 21 NUMBER AND LOOK AT THE DRAWING, AND IF I KNOW WHAT A HEAD 22 GASKET LOOKS LIKE, I CAN TELL YOU THAT IT'S A HEAD 23 GASKET. I DON'T KNOW WHAT IT'S FOR BECAUSE MY CUSTOMER 24 DOESN'T ALWAYS TELL ME WHAT IT'S FOR. 25 Q. RIGHT. 0187 1 A. SO THAT INFORMATION MAY OR MAY NOT BE IN THE 2 ENGINEERING FOLDER. 3 Q. WHO DESIGNS -- WHO PUTS TOGETHER THE CATALOGS? 4 A. IT WOULD BE THE PRODUCT PLANNING GROUP -- 5 Q. OKAY. 6 A. --IS THE GROUP THAT PUTS TOGETHER THE 7 CATALOGS. 8 Q. WHO'S IN CHARGE OF THE PRODUCT PLANNING GROUP? 9 MR. PARKER: AT WHAT POINT IN TIME? 10 MR. FISHBACK: ANY TIME. IT DOESN'T MATTER 11 WHEN, I JUST NEED TO KNOW. 12 MR. PARKER: IT MATTERS TO ME. 13 1959 TO 1980, DO YOU KNOW SOMEONE WHO WAS IN 14 CHARGE AT THAT TIME? 15 MR. FISHBACK: I DON'T NEED SOMEONE AT THAT 16 TIME. IF SOMEONE IS IN CHARGE OF THE PRODUCT PLANNING 17 GROUP, THEY CAN TALK ABOUT CATALOGS DURING -- WHETHER 18 THEY'RE IN CHARGE NOW OR BEFORE. 19 MR. PARKER: IT MAY OR MAY NOT BE TRUE. YOU 20 HAVEN'T LAID ANY FOUNDATION. 21 THE WITNESS: THE PRODUCT PLANNING GROUP IS 22 PART OF THE CLEVITE ENGINE PARTS GROUP. 23 BY MR. FISHBACK: 24 Q. ALL RIGHT. HERE'S THE SCENARIO. I'VE GOT A 25 WHOLE LOT OF PART NUMBERS. 0188 1 A. ALL RIGHT. 2 Q. BOXES OF PART NUMBERS, REFERENCED PART NUMBERS, 3 AND I DON'T HAVE THE VEHICLES THAT THE PARTS CORRESPONDED 4 TO, AND THE CONCERN I HAVE AND WHAT l'M TRYING TO Page 78