Document wD19YMRaEV9gkmogy7Dp9pNo3

Marcella Duncan 7-22-04.txt 11 MR. PARKER: AGAIN, WE'RE TALKING ABOUT THE 12 AFTERMARKET? 13 MR. FISHBACK: I'M ASKING, GENERALLY, WHAT KIND 14 OF SALES RECORDS. 15 THE WITNESS: I HAVE MICROFICHE. 16 BY MR. FISHBACK: 17 Q. DO THOSE INCLUDE AFTERMARKET SALES? 18 A. ONLY UP UNTIL VICTOR MANUFACTURING GASKET WAS 19 ACQUIRED BY DANA. IT WOULD LIST ALL CUSTOMER SALES UP TO 20 THAT POINT FOR THE VICTOR MANUFACTURING AND GASKET 21 COMPANY. 22 Q. BUT THOSE ARE ON THOSE DOB CARDS WE DISCUSSED 23 EARLIER? 24 A. YES. 25 Q. IS THAT RIGHT? SETTING ASIDE THE JOB CARDS -- 0213 1 I THINK THAT IS WHAT YOU CALLED THEM? 2 A. NO. SALES CARDS. 3 Q. SALES CARDS. SETTING ASIDE THE SALES CARDS -- 4 AND THAT'S THE ONES WITH THE PART NUMBER ON THE 5 RIGHT-HAND SIDE AND THE CARD NUMBER ON THE LEFT AND IT 6 GIVES THAT INFORMATION; CORRECT? 7 A. YES. 8 Q. SETTING ASIDE THOSE SALES CARDS, HAVE YOU EVER 9 SEEN ADDITIONAL SALES RECORDS SUCH AS INVOICES 10 PERTAINING TO AFTERMARKET SALES DURING THE 1960'S? 11 MR. PARKER: THAT WAS ASKED AND ANSWERED 12 TWO MINUTES AGO. 13 THE WITNESS: NO. 14 BY MR. FISHBACK: 15 Q. OKAY. AT THE LISLE OFFICE, ARE THERE SALES 16 DOCUMENTS, OTHER THAN WHAT'S CONTAINED ON THE MICROFICHE, 17 KEPT THERE? 18 A. YES. 19 Q. FOR WHAT YEARS? 20 A. WE KEEP QUOTES AND SOME CUSTOMER CORRESPONDENCE 21 FOR A PERIOD OF YEARS AS DEFINED IN THE DANA DOCUMENT 22 RETENTION GUIDE. 23 Q. SO WHAT YEARS DO YOUKEEP AT LISLE? 24 A. IT'S SIX TO TENYEARS ONTHE INFORMATION. 25 Q. SO IN LISLE, ILLINOIS, YOU HAVE NO INFORMATION, 0214 1 NO SALES DOCUMENTS -- SETTING ASIDE THE MICROFICHE, 2 AGAIN. NO SALES RECORDS, INVOICES, THAT GO -- THAT DATE 3 INTO THE TIME PERIOD 1959 TO 1980; IS THAT CORRECT? 4 MR. PARKER: OKAY. THAT'S EXPANDED THE TIME 5 FRAME, WHICH YOU CAN DO. BEFORE YOU TALKED ABOUT THE 6 '60S, AND NOW YOU'VE GONE INTO THE '70S AND UP UNTIL '80. 7 MR. FISHBACK: THAT'S BECAUSE SHE TESTIFIED 8 THAT THE DOCUMENT RETENTION POLICY WAS SIX TO TEN YEARS. 9 MR. PARKER: JUST SO IT'S CLEAR, THAT'S WHAT 10 WE'RE DOING. 11 BY MR. FISHBACK: 12 Q. DO YOU UNDERSTAND MY QUESTION? 13 A. UH-HUH. THERE'S SOME CUSTOMER CORRESPONDENCE 14 THAT'S OLDER THAN TEN YEARS. NOTHING CATEGORIZED, TYPED 15 AND MAINTAINED. 16 Q. WHY WOULD CUSTOMER CORRESPONDENCE BE KEPT PAST 17 TEN YEARS? 18 MR. PARKER: IF YOU KNOW. 19 THE WITNESS: I GOT ONE FILE CABINET IN MY AREA 20 THAT'S GOT CUSTOMER LETTERS AND CORRESPONDENCE AND SOME 21 OF THEIR TERMS AND CONDITIONS AND THINGS LIKE THAT, AND Page 89