Document wDQGYQxjkJOk4x6eXKjM2JLOE

Marcella Duncan 7-22-04.txt 15 GIVE US A PRINT OR IT'S A JOINT DESIGN BETWEEN THEIR 16 ENGINEERS AND OURS. 17 BY MR. FISHBACK: 18 Q. IS IT THE CUSTOMER, OR IS IT VICTOR DANA 19 THAT INDICATES THE SIZE OF THE GASKETS? 20 MR. CORCORAN: STEVE CORCORAN. LACKS 21 FOUNDATION, CALLS FOR SPECULATION, OVERBROAD, VAGUE AND 22 AMBIGUOUS. 23 MR. PARKER: JOIN. THIS CALLS FOR 24 SPECULATION. SHE'S IN SALES. IT SOUNDS LIKE AN 25 ENGINEERING QUESTION. 0082 1 MR. FISHBACK: I DON'T -2 THE WITNESS: THAT WOULD BE AN ENGINEERING 3 QUESTION. I'M NOT IN THE DESIGN END. 4 BY MR. FISHBACK: 5 Q. SO IS GENERAL MOTORS ONE OF YOUR CUSTOMERS? 6 MR. CORCORAN: STEVE CORCORAN. VAGUE AND 7 AMBIGUOUS, CALLS FOR SPECULATION. 8 THE WITNESS: NOT MY SPECIFIC CUSTOMER. 9 BY MR. FISHBACK: 10 Q. I MEAN ONE OF YOUR OWN CUSTOMERS. 11 A. I'M ALSO AN ACCOUNT MANAGER WITH ACCOUNTS I'M 12 RESPONSIBLE FOR AS WELL AS -- 13 MR. PARKER: THE QUESTION IS IS IT ONE OF YOUR 14 CUSTOMERS? 15 MR. FISHBACK: SHE'S EXPLAINING. LET HER 16 ANSWER THE QUESTION. 17 THE WITNESS: YOU MEAN ME PERSONALLY? 18 BY MR. FISHBACK: 19 Q. YES. 20 A. NO. 21 Q. IS GENERAL MOTORS AN ACCOUNT FOR WHICH YOU HAVE 22 SOME RESPONSIBILITY? 23 A. YES. 24 Q. HOW IS THAT -- WHAT IS YOUR RESPONSIBILITY IN 25 CONNECTION THEREWITH? 0083 1 A. I'M THE SALES OPERATIONS MANAGER FOR THE 2 DIVISION IN THAT CAPACITY. I'M RESPONSIBLE FOR SOME OF 3 THE POLICIES WITH WHICH WE DO BUSINESS WITH ALL OF OUR 4 GASKET CUSTOMERS. 5 Q. WHAT DO YOU MEAN "POLICIES"? 6 A. TERMS, CONDITIONS, GENERAL BUSINESS PRACTICES. 7 Q. IS IT YOUR UNDERSTANDING THAT THE GASKET 8 PRODUCT THAT DANA -- VICTOR DANA MANUFACTURES AND 9 SUPPLIES TO ITS O.E.M. CUSTOMERS, LIKE GENERAL MOTORS, 10 ARE FOR USE ON GENERAL MOTORS AUTOMOBILES? 11 MR. CORCORAN: STEVE CORCORAN. LACKS 12 FOUNDATION, CALLS FOR SPECULATION, OVERBROAD, VAGUE AND 13 AMBIGUOUS. 14 MR. PARKER: DO YOU STILL HAVE THE QUESTION IN 15 MIND? 16 THE WITNESS: SAY THAT AGAIN, PLEASE. 17 BY MR. FISHBACK: 18 Q. IS IT YOUR UNDERSTANDING THAT THE GASKET 19 PRODUCTS THAT VICTOR DANA MANUFACTURED AND SUPPLIED TO 20 ITS O.E.M. CUSTOMERS LIKE GENERAL MOTORS ARE FOR USE ON 21 GENERAL MOTORS VEHICLES? 22 MR. CORCORAN: STEVE CORCORAN. LACKS 23 FOUNDATION, CALLS FOR SPECULATION, OVERBROAD, ASSUMES 24 FACTS. 25 MR. PARKER: JOIN. Page 35