Document zo7g0E2OjEGzj2ndm4YELoRzg

--SEP. 13.2004 2:59PM RWDM LAW FIRM Multi-PageTM NO. 653 P. 7 Page 18 Page 1 on some water pumps. 1 Industries, were yon involved in the purchasing ax 2. Q.You mentioned distribution centers. What 2 all7 3 distribution -- what locations do you. remember 3 A-Purdbasing? 4 these distribution centers; do you remember where 4 Q.Yes. 5 they were located throughout the country? 5 A. No, not at that time. 6 A.For ga?7 6 Q.And what year did you get involved with the 7 Q.Well, the NAPA, you mentioned NAPA distribution 7 purchasing of product? 8 centers or the distribution centers that had the 8 A.Somewhere around '69, maybe '68, '69, some 9 products. . 9 purchasing. 10 MR. KlLEY:. Over what time frame? 10 Q.Okay. What sort of purchasing were you involved 11 Q.(by MR. ABBOT) Let's go from 1966 when you started 11 then? 12 to 1980. 13 A. All right, GAP stqtplied approximately 14 to 17. 12 A. Once the plant manager took over as general manager 13 of die two plants, I would help out sometime if we 14 Q. 14 to 17 distributioacenters? 14 were - say someone was off on vacation or out sick 15 A. Yes. 15 or something, I would help out on purchasing. I 16 Q.Who owned those distribution centers? 16 talked with some of the people, I ordered some 17 a. Part of them were owned by Genuine Automotive Parts 17 brake lining. 18 and some of were owned by I think the Boltons owned 18 Q.You ordered all different type of products, isn't 19 Des Moines and Dewitt I guess the rest of them 19 that correct? 20 were GAP. Only those two were probably Bolton. 20 A. Ordered American Brakebloc. 21 Q. Could you, just based oh your recollection, today 21 Q.No, I'm jost talking, beyond that; all sorts of 22 let me know, identify for me, where those 22 products from American Brakebloc? 23 distribution centers were located? 23 A. Sure. I was not a purchasing person. Ijust 24 A. Dallas, Houston, San Antonio, Kansas City, St 24 filled in. 25 Louis, Mount Vernon, Milwaukee, Stevens Point, 25 MR. ABBOT. That's all die questions I Page 19 Pa? 1 Indianapolis, Grand Rapids, Detroit, Fort Wayne, 1 have, thank you. 2 Louisville, Knoxville, and Nashville. I left out 2 MR. DICKEY: I don't have any questions. 3 two, Des Moines and Dewitt 3 Do you have anything, Pat? 4 MR. DICKEY: You didn't mean Mount Vernon, 4 EXAMINATION 5 Virginia, did you? 5 BY MR. RILEY: 6 THE WITNESS: No. 6 Q.I just want to clarify one point. .Before the late 7 Q. (BY MK_ ABBOT) Of the distribution centers you 7 1980's, if somebody went into a napa store and % 8 mentioned, were there any distribution centers 8 a box of either brake linings or brake shoes or 9 you're aware of that are on the east coast? These 9 disk brakes that had ft NAPA logo on the box, 10 all seem to be in the middle of the United States. 10 whose friction product would be inside that box? 11 a. Central United States. None on the east coast. 11 A. To my understanding, it would be Abex. 12 Q.None on the east coast? . 12 Q.Okay. 13 A-No. 14 Q.What about the west coast? 15 A.No,sir. 16 Q.And, the follow-up on that, you would have no 17 knowledge of the distribution centers in the east 18 coast or who they were buying products from, what 19 they were supplying hapa stores with on the east or . 20 west coast? 21 A. R was always my knowledge what I was told, if they 22 were Napa *ey were buying American Brakebloc. 13 EXAMINATION 14 BY MR. ABBOT: 15 Q.And the basis of your understanding even at that 16 late time m the late 1980's-- 17 MR. RILEY: I said before the late 1980's. 18 Q.(by MR. abbot), I'm sorry, inthat time frame tha 19 Mr. Riley was referencing, the basis of your 2<T knowledge for that statement is what? 21 a. Sometimes I went to these DC'8 and I could see the 22' product 23 Q. Give me one second. Let me check my notes for a 24 second. 25 In 1966 when you started with Genaut 23 Q.Did you ever see -- 24 Air had American Brakebloc on the labels. Our B, 25 our RS. aB's all those back in that period of time JOHN M. BOWEN & ASSOCIATES - (816) 421-2876 Page 18 - P: