Document ppOY5gxKn8ELD6G2R8ZZX4K1w

Marcella Duncan 7-22-04.txt 20 CORPORATION AS PART OF YOUR NORMAL SALARY TO BE HERE; 21 CORRECT? 22 A. YES. 23 Q. ARE YOU GETTING ANY ADDITIONAL PAY FOR YOUR 24 PARTICIPATION IN THIS DEPOSITION? 25 A. NO. 0060 1 Q. HAVE YOU RECEIVED A -- STRIKE THAT. 2 WHEN YOU FIRST -- SINCE YOU'VE BEEN TESTIFYING 3 IN DEPOSITIONS, HAVE YOU BEEN PROVIDED BONUSES OR SOME 4 ADDITIONAL INCENTIVES FOR YOUR WORK TESTIFYING IN 5 DEPOSITION AND AT TRIAL IN ADDITION TO YOUR OTHER 6 RESPONSIBILITIES? 7 A. NO. 8 Q. DID THEY TELL YOU YOU WERE GOING TO HAVE TO 9 TESTIFY AT DEPOSITION AND AT TRIAL AND OTHER THINGS WHEN 10 YOU ACCEPTED YOUR CURRENT POSITION WITH DANA? 11 A. NO. 12 Q. WERE YOU SURPRISED TO LEARN THAT YOU WERE GOING 13 TO HAVE TO GIVE DEPOSITION AND TRIAL TESTIMONY? 14 MR. PARKER: OBJECTION; ARGUMENTATIVE, 15 RELEVANCE. 16 CONTINUE TO ANSWER, GO AHEAD. 17 THE WITNESS: THIS WAS NOT PLANNED OR GIVEN TO 18 ME AS PART OF A JOB RESPONSIBILITY AT ANY TIME. 19 BY MR. FISHBACK: 20 Q. OKAY. I THINK YOU ANSWERED THIS QUESTION. IF 21 YOU HAVE, I APOLOGIZE. 22 THERE WERE ASBESTOS-CONTAINING HARD GASKETS 23 MANUFACTURED BY VICTOR THAT WERE MANUFACTURED DURING THE 24 1968 TO 1970 TIME PERIOD THAT YOU KNOW OF? 25 A. YES. 0061 1 Q. ARE THERE OTHER TYPES OF GASKETS BESIDES HARD 2 GASKETS AND SOFT GASKETS THAT YOU GENERALLY CATEGORIZE 3 THEM AS? 4 A. NO. 5 Q. AND, AGAIN, YOU'RE NOT THE BEST PERSON TO TALK 6 ABOUT THE PARTICULAR SPECIFICATIONS FOR 7 ASBESTOS-CONTAINING HARD GASKETS? 8 A. NO, I'M NOT. 9 Q. AND MR. KOZINSKI IS THE MAN YOU WOULD ASK IF 10 YOU HAD HAD QUESTIONS ABOUT HARD GASKETS AND THEIR 11 COMPONENT MATERIAL PARTS? 12 A. YES. 13 Q. WITH RESPECT TO THE FILE CARDS, AND 14 PARTICULARLY THOSE STORED AT THE ENGINEERING VAULT IN 15 LISLE, IS IT TRUE THAT ALL OF THE ENGINEERING CARDS FOR 16 HARD GASKETS ARE STORED IN THE ENGINEERING VAULT AT 17 LISLE? 18 MR. PARKER: CALLS FOR SPECULATION. 19 YOU CAN ANSWER, TO THE EXTENT YOU KNOW. 20 THE WITNESS: PROBABLY, YES. 21 BY MR. FISHBACK: 22 Q. WHY "PROBABLY" AND NOT "CERTAINLY"? 23 A. BECAUSE I'M NOT CUSTODIAN OF THOSE FILES. 24 Q. WHO IS? 25 A. YOU'LL HAVE TO ASK RICH KOZINSKI THAT QUESTION. 0062 1 I COULDN'T TELL YOU THAT. I MEAN I DON'T KNOW. 2 Q. SURE. BY THE WAY, HAVE YOU EVER ATTENDED ANY 3 CLASSES OR RECEIVED ANY EDUCATIONAL INSTRUCTION ON HOW TO 4 BE A WITNESS AT TRIAL OR IN DEPOSITION? Page 26