Document qa2avQmkk38y6MjKBRR9X1x6j

/ if I Hicks, et al. v. ACandS, Inc., et al. 6/1/01.-Paul L LeCour ' Page 10 Page 12 1 2 .3 4 5 6 7 89 ' 10 11 12 13 14 15 16 17 18 19 20 . 21 22' 23 24 25 to look i Exhibit A.to that deposition, which are the areas of inquiry for today's deposition? A. Yes. Q. Were there any areas on that Notice of Deposition, Exhibit A, that you are unable to testify to today? '! A. No. Q. Is there anyone at Genuine Pans who is more knowledgeable about any panicular area on Exhibit 1? . A. No. Q. Is there anybody at Genuine Pans who' is equally as knowledgeable as you are about any topic that's listed in the Notice of Deposition for,today? A. No. Q. Is there anyone with whom you have consulted' prior to today's deposition to obtain information for today's deposition? MR. RILEY: Objection as to it inquires into attorney-client privilege. With the exception of counsel, he can answer. ' THE WITNESS: No. . '' Q. (By Mr. Dumler) Are there any documents that you have reviewed in preparation for today's deposition? A. Yes. Q. What document have you reviewed? 1 yesterday. 2 Q. (By Mr. Dumler) I'm sorry. That's the file 3 . you reviewed in connection with today's deposition? 4 A. Yes. 5 Q. When did you review the document? 6 A. Several months ago. 7 Q. And you started that file when you began 8 working in Atlanta? 9 A. Yes. 10 Q. .What was the reason that you started keeping II that particular file? 12 A. Because 1 wanted to know what had transpired 13 over the years. 14 Q. So is this a file that's related specifically 15 10 Genuine Parts? 16 A. It's related to my business with Genuine 17 Parts. ' 18 Q. When you say you wanted to know what 19 transpired over the years, with respect to what issue? 20 A. All product lines. 21 Q. So anything that was related to-a product line 22 or an issue which you were dealing with, you would put 23 in this particular file? 24 A. Yes. 25 . Q. I'm going to also ask the court report to mark Page 11 Page 13 1 A. My personal. 2 Q. I'm sorry. Your personal file? 3 A. Uh-huh. 4 Q. Where do you keep your personal-file? 5 A. In my office. ... 6 Q. What is-contained in your personal file? 7 A. Correspondence. 8 Q. What - 9 MR. RILEY: Ifl can interrupt, were those 10 documents produced? 11 THE WITNESS: Yes, all documents were 12 fumed over to legal. 13 Q. (By Mr. Dumler) Is the personal file that you 14 maintain a file dealing with issues related to asbestos '.15 litigation? Is that why you maintained the file? 16- A.' No. It's just a general file. 17 Q. When did you start keeping your personal file? IS A. Ever since I worked at the company -- well, 19 ever since I've been in Atlaota. 20 Q. What year was that? 21 . A. 1976. 22 Q. So the documents (hat were produced. I did see 23 a notation that says "Paul LeCour's File." That's the '24 file you reviewed yesterday; is that correct? 25 MR. RILEY: No. The file you reviewed l this Exhibit No. 2) which is Genuine Parts Company's 2 Answers to the Plaintiffs Case-Specific 3' Interrogatories. 4 (Plainlifls' Exhibit LeCour 2 was marked.) 5 Q. (By Mr. Dumler) Mr. LeCour, ifl could turn 6 you to the back of this document, there's an exhibit ' 7 . which lists the deposition transcripts. And your name 8 appears on there a couple of times. 9 My question is: Are there any depositions 10 that you have given that do not appear on Attachment B II to the Case-Specific Interrogatory Answers? 12 A. Yes. 13 Q. What other depositions have you given that are 14 not-on that Attachment B? IS A. It was personal business. 16 Q. No other depositions related to Genuine Parts?. 17 A. No. . 18 Q. And the personal business did not relate to 19 asbestos? 20 . A. It did. 21 Q. How did it relate to asbestos? 22 * A. It was a company-owned business. And we were 23 called because there was a -- they wanted to know if our 24 company business ever used the products. 25 MR. RILEY: Clarify what company you're WHEELER REPORTING company; INC., 404-351-4577 4 (Pages 10 to 13) i