Document omRGwD3e3j0Bz8o6Bg793rkk8

Marcella Duncan 7-22-04.txt 21 INDUSTRIAL PRODUCTS OF DANA. 22 Q. OKAY. 23 A. ALONG WITH THE OIL SEALS. 24 Q. SO HOW -- SORRY? 25 A. THAT DIVISION WAS CHARGED FOR THAT SQUARE 0232 1 FOOTAGE THAT WAS USED FOR THE INVENTORY IN MY OFFICE 2 SPACE. 3 Q. VERY COMPLICATED. HOW LONG DID YOU HOLD THAT 4 POSITION? 5 A. THEY MOVED IT DOWN TO INDIANAPOLIS IN 1984. 6 IT CHANGED THE WAY --IT WENT TO A DIFFERENT DIVISION 7 CALLED THE POWER AND TRANSMISSION SALES DIVISION, 8 AND I COUPLED THAT UP WITH SEVERAL OTHER MANUFACTURING 9 PRODUCTS OF OTHER DANA DIVISIONS POWER TRANSMISSION 10 PRODUCTS AND SOLD ALL SEVEN DIFFERENT LINES OUT OF THAT 11 WAREHOUSE IN INDIANAPOLIS. 12 Q. WHEN DID YOU START IN THE INDUSTRIAL 13 DISTRIBUTION WAREHOUSE, OIL SEALS, WHAT YEAR? 14 A. 1980. 15 Q. AND YOU LIVED IN INDIANAPOLIS IN 1984? 16 A. YES. 17 Q. AND HOW LONG WERE YOU IN THE INDIANAPOLIS 18 FACILITY? 19 A. I LEFT INDIANAPOLIS IN 1987. 20 Q. AND THE POSITION YOU HELD THERE STILL INVOLVED 21 THE CONSOLIDATION OF ALL OF THESE -- THE OIL SEALS -- 22 INDUSTRIAL DISTRIBUTION FOR OIL SEALS AND ALL THE 23 OTHER -- 24 A. NO. 25 Q. IT CHANGED AT SOME POINT? 0233 1 A. YES. 2 Q. WHEN DID YOU CHANGE? 3 A. 1985. I BECAME THE CUSTOMER SERVICE MANAGER 4 FOR THE INDIANAPOLIS MIDWEST PARTS DEPOT FOR THE 5 WAREHOUSE OPERATIONS DIVISION. 6 Q. WHAT DIVISION? 7 A. IT WAS CALLED THE WAREHOUSE OPERATIONS DIVISION. 8 Q. WHAT DID IT DO? 9 A. THAT WAS ONE OF THE DISTRIBUTION CENTERS FOR 10 ALL OF 11 ONES. 12 Q. INCLUDING GASKETS? 13 A. INCLUDING GASKETS. 14 Q. INCLUDING THE OIL SEALS? 15 A. INCLUDING OIL SEALS. 16 Q. EVERYTHING? NUMEROUS PRODUCTS? 17 A. YES. SAME THING AS WHAT WAS IN CHURUBUSCO. 18 Q- ALL RIGHT. WHAT WERE YOUR SPECIFIC JOB DUTIES? 19 A. I WAS THE CUSTOMER SERVICE MANAGER, AND I HAD A 20 DEPARTM 21 PHONE, 22 HAD IN 23 Q. O.E.M. AND O.E. SERVICE EXCLUSIVELY? 24 A. NO. 25 Q- INCLUDING AFTERMARKET THEN? 0234 1 A. THERE WAS NO O.E.M. AND O.E. SERVICE. 2 Q. JUST AFTERMARKET? 3 A. AFTERMARKET. 4 Q. THIS WAS IN THE SAME TIME IN THE MID 1980'S? 5 A. NO, 1985. Page 97