Document pmQ4qKXjewvqze18Kpk2XzOgD

Hicks, et al. v, ACandS, Inc., et al. 6/1/01 - Paul L. LeCour' Page 134 Page 136 .1 A. This is a NAPA Rayloc American Brakcblok ad. 2 It's titled, "We want to stop you every time." 3 Q. Are you familiar with that ad campaign? ' 4 A. Mo, 1 am not familiar with the ad campaign. ' .5 Q. Do you know when this particular document was . 6 produced? 7 ' A, Mo, 1 do not. 8 Q. Do you know who would know? 9 A. Lee me read it here first, and I'll see. 10 Q. Sure. Take your time. 11 A. Again, that would be marketing and sales and 12 also, at that time, people that were in sales at Abcx. 1) That was a document that looked like it was put together |0. by Abes. 15 Q. There's a reference in there to - 1 don't 16 want to misquote it, so let me have the document back - . 17 if 1 can. It says, "Asbestos free is a better brake." .13 Are you familiar with that statement in that 19 paragraph (indicating)? 20 A. Uh-huh. 21 Q. Can you tell me at what point in time did that 22 statement become true? 23 A. Today it's not true. 24 Q. So from your perspective, as of now, the brake 25 systems are not as effective or good as the asbestos 1 '2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1990s, did Rayloc ever advise any of its manufacturers' of friction products that it would only accept non-asbestos products by a certain date? . A. Repeat your question. O. Sure. At.any time, did Rayloc ever advise any of its suppliers of friction material that they would only purchase non-asbestos products by a certain date? A. Not to my knowledge, no. Q. Am 1 correct that the only reason'that Rayloc stopped selling asbestos-containing products was the ban on asbestos? A. We were preparing for that, that's correct. Q. 1 understand that. But my question is: The only reason that you stopped selling asbestos-containing products was that there was a ban placed or you believed there would be a ban placed on the sale of those products? MR. RILEY: Now, he's not testified to that.. Q. (By Mr. Duntler) Thai's my question. A.. Repeat it again. Q. Sure. The only reason that Rayloc stopped manufacturing asbestos-containing products is the company believed that there would ultimately be a ban placed on the manufacturer of those products? Page. 135 "i Page 137, 1 brake systems that you produced back in the 70s? 2 A. I'm saying that they're not better lhan. They 3 ean be equal to. But that's a bunch of hype and sales 4 pitch. 5 Q. At w.hat point in time, from your opinion, 6 . did the asbestos-free brakes become equal to the 7 asbestos-containing brakes? 8 A. It would have been -- to our satisfaction to 9 perform, it would have been in the '90s. 10 Q. Can you tell me'what efforts Rayloc made to 11 investigate or engineer or assist in the development of 12 an asbestos-free.brake prior to the 1990s? 13 A. We never did.anything to develop, to compound. 14 any type of formula. 15 The only thing we did was say, give us a piece 16 of friction material that works equally as well as what 17 we currently have and is as safe as what we have and 18 will stop that car under all conditions. ' 19 Q. Am I conect the answer is nothing?' 20 A. Nothing.no. 21 MR. RJLEY: The answer is they don't make 22 friction products. 23 THE WITNESS: We don't make friction 24 products. 25 Q. (By Mr. Duntler) At any time prior.to the 1 A. Yes. " 2 Q. Now. whai number are we on? 3. (Plaintiffs' Exhibits LeCour 25 and 26 . 4 were marked.) 5 Q. (By Mr. Dumler) I'm going to give you what's 6 been marked as Exhibit 25 and 26, which appear to be the 7 same document but addressed to different people. . 8 Do you see that document? 9 A. Yes, 10 Q. Are you familiar with those documents, 25 11 and 26? 12 A. Yes. 13 Q. All right. And you are the author of that 14 document? 15 A. Yes. 16 Q. Okay. One says,'from: Engineering" and the 17 other says, "From: Paul LeCour." But both are from 18 you, I take it? 19 A. Yes. 20 ' Q. And this document is your notification to 21 everyone internally at Rayloc that you've got to start 22 putting markings on your packages that your product 23 contains asbestos? 24 A. Yes. 25 . Q. All right. Now I'm going to take one of them WHEELER REPORTING COMPANY, INC,, 404-351-4577 35 (Pages 134 to 137)