Document v1RqqYM2eg5dXYnLqjgq827RY

THOMAS DICKSON Page 30 Page 32 1 1 Q. And what was yourjob duty there? 2 A. To sell service parts to the OEM's, the 3 original equipment manufacturers. 4 Q. And what type of service parts were you 5 selling? 6 A. Transmission, clutch, universal joint and 7 axle. 8 Q. Was there another individual that would be 9 selling gasket materials? 10 A. I'm sure there was. I -- I don't even know 11 at that time whether we sold gasket materials. 12 Q. So you simply don't have any knowledge of 13 when Dana began selling gasket materials? 14 A. Correct 15 Q. Nor do you have any knowledge as to when they 16 sold gasket materials whether asbestos was 17 incorporated as a component of those gaskets? 18 A. That's correct 19 Q. Did you, when you were in the service parts 20 department, sell any parts to domestic automobile 21 manufacturers for passenger cars? 22 A. Pm sure some ofthe parts that we sold to 23 the Chrysler, Ford and GM's went into light track. As 24 far as passenger car, I have no idea if any of those 25 parts went into passenger cars. 1 manufacturers include any foreign companies? And by 2 "foreign companies," I don't necessarily mean that | 3 they're located outside the United States. They may 4 have distributors within the United States. 1 1 5 A. No, at that time Mack Tracks wasn't a 9 6 foreign-owned company, so -- Mack, Brockway, Diamond 1 7 Rio were the main OEM's. We put on presentations to | 8 their dealer organizations, but none of those sales j 9 were to foreign manufacturers that I knew of. i 10 Q. Was there an individual in your division that 11 sold to West Coast? | j 12 A. Yes. 13 Q. And in that capacity would he be selling to 14 those West Coast entities that you talked about 15 earlier: Kenworth, Peterbilt, et cetera? j 16 A. Yes. 17 Q. And who are, to the best of your knowledge, 18 the West Coast manufacturers that bought Dana's j J 19 clutches? 20 A. The ones I named: The Peterbilt, Kenworth, 21 Freightliner. | I j 22 Q. How about International Harvester? 23 A. International Harvester I consider Midwest, 1 24 and they were located in Fort Wayne at the time. We j 25 sold to diem. | Page 31 Page 33 1 Q. During the time that you were with the 2 service department, did you sell any parts to foreign 3 car manufacturers or foreign truck manufacturers? 4 A. No, I didn't. 5 Q. Was that because of a limitation of your job 6 or is it because, to your knowledge, Dana didn't make 1 Q. GMC? Is that East Coast, West Coast -- 2 A. GMC we sold some to, but GMC got out of the 3 heavy truck business and I can't give you the date. 4 So the sales to GM -- GMC was not a major clutch 5 customer. 6 Q. When did the West Coast sales begin, if you j | f 1 j j 7 such sales? 8 A. In 1967 I don't think we made many sales to 9 foreign products -- or foreign car manufacturers or 7 know? 8 A. Ever since the West Coast started making 9 heavy trucks, I think they had Spicer-type clutch in 10 track manufacturers. 11 Q. How long were you in that job? 12 A. About three, four years. 10 them. 11 Q. Do you know whether any of those clutches 12 were sold to Mercedes-Benz for their trucks? j j 13 Q. By the time you left in late 1960's/early 13 A. Mercedes-Benz I don't believe was even making j 14 1970's, is your statement regarding the foreign 14 vehicles in the United States at that time, and they j 15 manufacturers still accurate? 15 hadn't purchased Freightliner by then either. 16 A. Yes. 17 Q. Where did you go after you left the service 18 department? 16 Q. What about Marmon? 17 A. We supplied clutches to Marmon at some time. 18 I don't consider Marmon a foreign clutch manufacturer, j j 19 A. I went with the clutch division as an eastern 20 region sales representative -- sales and service 19 but -- 20 Q. No, I was just wondering if you had sold to 21 representative. 22 Q. And who were you selling to? 23 A. I was selling to the East Coast original 24 equipment manufacturers. 25 Q. And did those original equipment 21 them. 22 A, Yes. Any of the heavy-duty -- any of the 23 18-wheeler-type truck builders we probably supplied 24 some sort of clutch to. 25 Q. Is there any way of determining which tracks Henjum Goucher Reporting Services 1-888-656-DEPO 9 (Pages 30 to 33)