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ROGER HOBBIE Page 10 Page 12 1 Q How current is the information on that document? 2 A It is up-to-date. 3 Q I will have some additional questions later on but I 4 wanted to go to a couple of other items before we do that. I 5 will show you a couple other documents preliminarily. I would 6 like to have the following marked 2,3 and 4. 7 (Exhibit 2, memo-1/14/87; Exhibit 3, monthly 8 report; Exhibit 4, monthly report, were marked for 9 identification.) 10 Q I have had those items marked and am showing them to 11 Mr. Quick and the witness. I will describe them before I ask 12 any questions. Mr. Hobbie, what I will do is, I have some 13 preliminary questions about each of these documents. I won't 14 go into anything substantive until you have had a chance to 15 look at them. I have a couple of preliminary questions. 16 According to your CV, you first began working 17 for Eaton in 1959; is that correct? 18 A That's correct. 19 Q What was the name of the company when you first 2 0started working for them? 21 A Eaton Manufacturing Company. 22 Q Where were they located? 23 A East 140th street in Cleveland, Ohio. 2 4 Q How long did you continue to work for Eaton until 2 5 you left their employ? 1 A Yes. 2 Q Can you describe generally what you did in that 3 position? 4 A Basically, I was domiciled in Portland, Oregon and 1 5 called on customers in the northwestern United States and 6 western Canada plus Alaska and the Yukon, both the truck 7 manufacturers that were located in that area and truck fleets 8 and dealerships and basically represented the company and our 9 products from the axle and brake product line area. 10 Q Exactly, what were you trying to sell, generally? 11 A General ly, we were trying to promote our 12 specification of our components in vehicles where a fleet 13 would specify different components when they were ordering new 14 trucks and just basically familiarizing them with Eaton 15 components and providing a contact so that we informed them 16 about our products and their use. 17 Q Can you describe some of the component parts that 1B you were representing to the customers? 19 A Yes. Drive axles that ranged from weight ratings of 20 15,000 pounds up to 44,000 pounds and generally 16 and a half 21 by seven inch S-cam brakes. Basically, that's it 22 Q I assume you had to have a working knowledge of how 23 the braking systems were used and what materials were used 2 4 within the braking systems? 25 A Yes. Page 11 Page 13 1 A Almost 38 years. 2 Q Based on the information in your CV, it looks like 3 you last worked for Eaton as an employee in 1997; is that 4 correct? 5 A That is correct 6 Q Between 1959 and 1997, did you work for anyone other 7 than Eaton Corporation? 8 A No. 9 Q Your firstjob it looks like according to your CV 10 between 1959 and 1970, you worked as an engineering test 11 technician for Eaton axle and brake divisions; is that 12 correct? 13 A Yes. 14 Q Can you generally describe what you do as an 15 engineering test technician? 16 A Basically worked in a lab area where we conducted, 17 oh, both development tests and quality audit-type tests on 18 axle components using dynamometers and test trucks and also on 19 foundation brake products using primarily at that time test 2 0 trucks. 21 Q Obviously, your testing would include brakes? 22 A Yes. 23 Q Between 1970 and 1974, it looks like you then moved 2 4 on to the district sales and engineering manager for Eaton; is 25 that correct? 1 Q From 1974 to 1977, it looks like you were the 2 manager of the engineering test facilities and application 3 engineering for the axle division; is that correct? 4 A Yes. Brake product had been moved basically out of 5 the axle division when the brake division was formed, about 6 the time I moved back to Cleveland. 7 Q Were you working in the brake division between '74 8 and '77? 9 A No. 10 Q What division were you working for? 11 A The axle division. 12 Q You were back in Cleveland at that point? 13 A Yes. 14 Q Generally, describe what your responsibilities were 15 as the manager of the engineering test facilities. 16 A Basically, I was the manager ofthe facility that I 17 had worked in before where 1 was overall supervisor of setting 18 up tests and managing the people that conducted those tests. 19 Q What kind of tests generally were you supervising? 20 A Dynamometer tests, truck tests where we used test 21 trucks to put new products through durability testing tilings 22 like that before they were released for sale to our OEM 2 3 customers. 24 Q What is a dynamometer test? 25 A Basically where you mount an axle between two load 4 (Pages 10 to 13) (800) MERRILL LEGAL SOLUTIONS 325-3376 www.MerrillCorp.com 5cfe6bcd-afe7-469e-b187-b081 ecda30a3