Document pm8q3K07j76VQYxMYJY9ZXeaj

Marcella Duncan 7-22-04.txt 7 OCTOBER, SEPTEMBER, OCTOBER, TIME FRAME FOR THE COMING 8 YEAR AND 10 YEARS OUT. 9 Q. OTHER THAN THE SALES RECORDS, ARE THERE OTHER 10 RECORDS THAT YOU'RE AWARE OF THAT CONTAIN SALES 11 INFORMATION FOR THE TIME PERIOD 1959 TO 1980? 12 A. SAY THAT AGAIN, PLEASE. 13 Q. OTHER THAN THE SALES RECORDS THAT YOU'VE JUST 14 REFERENCED, ARE THERE OTHER TYPES OF RECORDS OR MATERIALS 15 THAT MEMORIALIZE SALES TO O.E.M. DURING THE TIME PERIOD 16 OF 1959 TO 1980 THAT YOU'RE AWARE OF? 17 A. YES. 18 Q. WHAT OTHER TYPE OF SALES ARE YOU AWARE OF? 19 A. MICROFICHE SALES RECORDS. 20 Q. THOSE ARE AT THE REPOSITORY; CORRECT? 21 A. YES. THERE IS A SET AT THE REPOSITORY. 22 Q. DO YOU ALSO HAVE A SET IN YOUR OFFICE? 23 A. YES, I DO. 24 Q. AND THOSE GO BACK FOR HOW LONG? 25 A. WE FOUND 1940'S DATES ON THERE. 0092 1 Q. HOW ARE THOSE DOCUMENTS ORGANIZED? 2 A. BY PART NUMBER, BY GASKET -- VICTOR PART 3 NUMBER. 4 Q. ARE THEY ORGANIZED BY O.E.M. PART? IN OTHER 5 WORDS, GENERAL MOTORS, FORD, ET CETERA? 6 A. NO. 7 Q. SO TO UNDERSTAND THE MICROFICHE, YOU HAVE TO 8 KNOW WHAT THE PART NUMBERS ARE? 9 A. CORRECT. 10 Q. AND YOU ALREADY INDICATED THAT THERE WAS A 11 LEDGER THAT CROSS REFERENCES THE PART NUMBERS AS TO WHAT 12 THEY ARE? 13 A. NO. WHAT I TALKED ABOUT BEFORE WAS CATALOGS. 14 THE CATALOGS WE DUST SPOKE ABOUT FOR APPLICATION, THAT'S 15 GOT THE PART NUMBERS IN IT -- 16 Q. OKAY. 17 A. -- RELATING TO A SPECIFIC GASKET APPLICATION. 18 Q. SO IF I WANT TO REVIEW THE MICROFICHE SALES 19 RECORDS, I NEED TO HAVE THE CATALOG FROM THE SPECIFIC 20 YEAR. 21 LET'S DUST TAKE A YEAR, 1965. OKAY? IF I 22 WANTED TO REVIEW THE MICROFICHE SALES RECORDS FROM 1965 23 TO LEARN THE AMOUNT OF SALES TO SAY, FOR EXAMPLE, GENERAL 24 MOTORS, I WOULD NEED A COUPLE OF THINGS, INCLUDING THE 25 MICROFICHE SALES RECORDS; CORRECT? 0093 1 A. THAT'S THE ONLY THING YOU'D HAVE FOR AN O.E.M. 2 Q. I SEE. THERE'S NO CATALOGS FOR O.E.M.? 3 A. CORRECT. 4 Q. SO IF I WANTED TO -- IF I WAS REVIEWING THE 5 MICROFICHE SALES RECORDS FOR O.E.M., HOW WOULD I KNOW 6 WHAT PARTS OR PRODUCTS WERE BEING SUPPLIED TO THE O.E.M? 7 MR. CORCORAN: STEVE CORCORAN, LACKS 8 FOUNDATION, CALLS FOR SPECULATION, OVERBROAD. 9 MR. PARKER: CAN YOU DUST READ THE QUESTION 10 BACK? 11 MR.CORCORAN: VAGUE AND AMBIGUOUS. 12 MR. PARKER: STEVE, SHE'S DUST GOING TO READ 13 IT BACK. 14 (THE RECORD WAS READ BY THE REPORTER AS 15 FOLLOWS: 16 "QUESTION: SO IF I WANTED TO -- IF I WAS 17 REVIEWING THE MICROFICHE SALES RECORDS FOR Page 39