Document j21gLa0rXV4bB3Y4oQRmpb2N

Hicks, et al. v. ACandS, Inc., et al. 6/1/01.-Paul ,L. LeCour . Page 158 Page 160 1 2 3 4 5 6 7 8 9 10 II 12 13 M 13 16 17 18 19 20 21 22 23 24 25 Q. Have you visited the South Plain/ield Distribution Center? A. I cannot recall. Q. Are you aware of any documents related to the sales from the South Plainfield Distribution Center to any of the jobbers in that area? A. No, I'm not. Q. Have you made any efforts to look for any? A.. No, 1 have not. Q. Do you know where they would be located if they did exist? . A. Well, if they exist, they would be at the distribution center. What time frame are you talking about? Q. i960 through 1980. A. Willi our retention policy, 1 don't think that you will find anything going back to that time period. Q. At what point -- MR. RILEY: For the record, while he did not, a search was made; and there were no . records. Q. (By Mr. Dumler) At what point in lime did the distribution centers begin to computerize their sales to local jobbers?. . A. I can't recall the exact -- well, actually, 1 A. 1 don't know when marketing conferences 2 started. It had to be prior to 1971 when 1 started with 3 the company, because 1 heard, you know, they had other 4 ones. . 5 Q. All right. So from '71 through the '80s, 6 there was an annual NAPA marketing convention? 7 A. Yes. 8 Q. How many days did they span? 9 A. iN'iirmylly ihue's one day. id p.' Were there presentations, or is it like 11 a lair, where you go and there are booths? . . 12 A. All the above. li was -- wc had display 13 tables Tor the manufacturers. And then, of course. 14 they had presentations that were put on by NAPA. 15 Q. At any of these national marketing 16 conventions, was there any presentation or discussion ' 17 aimed at alerting any of the jobbers to the dangers of 18 asbestos? 19 A. No, there was not. 20 Q. Al any of the national marketing conventions. 21 was there any presentation or any effort to alen 22 jobbers that there should not - that mechanics should 23 not be grinding brake shoes or brake pads? 24 A For what reason? 25 Q. At all. Was there any effort to say - ' Page 159 1 TEMS was the system. And that had to be in the '80s. 2 MR. DUMLER: AU right. Let's lake 3 a two-minute break so 1 can look at my notes 4 here. 5 (Recess was taken.) 6 Q. .(By Mr. Dumler) Mr. LeCour, am 1 correct that 7 Genuine Pans ~ strike that -- ihat NAPA held annual or 8 national meetings, convention-type meetings? I'm not 9 correct in the way you're looking at me? 10 A. Yes. II Q. 1 am correct? < 12 A. Yes. 13 Q. What was the purpose of those? Were they ' . 14 . conventions'.1 What were they? IS A. They were called marketing conferences. And 16 they were tu display what's coming up for the'next year, 17 what our motto was going to be, and any new products IS available. And it was, you know, a get-together with 19 our customers, the NAPA.jobbers. 20 Q. And were they in fact held annually? 21 A. Annually. 22 Q. How many days? Was it a multi-day event? 23 MR. RILEY: Can we put a time home on it 24 . as to when they started? 25 Q. (By Mr. Dumler) When did they start? Page 161 1 A. Well, our sales materials said it is not 2 necessary to grind our product, just go ahead and 3 install it, and yuu can get more curs into your garage 4 a day and make more money. Thai was from a performance 5 reason only. U had nothing to do with any other 6 reason. ' 7 Q. There was never any indication that there 8 might be a safety reason not to grind the shoes or pads? A. Safety. If they were ground and you ground 10 (hem incorrectly, you could create a locktd-up wheel, It creating a safety hazard by causing the car to go out 12 .of control. ", 13 So that would have bwn part oT the isjue. >4 Q. Was there a publication that was sent to NaPA IS jobbers by Na Pa? 16 A. Many publications. What are you referring to? 17 Q. Well, how many publications are there? .18 There's somethini* called NAPA Outlook? 19 A. Napa Outlook is not that old. 20 Q. When was that started? 21 A. t can't recall, but it was not in the '70s, 22 to my recollection. 23 0- Well, maybe l ean help you. 24 MR. RILEY: Okay. He's not being offered 25 as 3 witness on behalf ul'NAPA. "wheeler REPORTING COMPANY, INC....-404-351-4577 41 (Pagts 15S to 161)