76. Ms. Martha Williams
the current president of Stylemaster
Stylemaster's filing in 2002, Ms.Williams was the president, chief executive officer, and chief operating
officer of Stylemaster
relevant times, Ms. Williams
was responsible for contacting vendors and
authorizing the purchase of molds on
Stylemaster's behalf.Ms. Williams
was also responsible for
submit drawings and other documents pertaining to the design of each mold.Ms.Williams
would also seek the advice and input of Mr. Raymond C. Wenk, Sr.
95. Ms. Williams
was responsible for
final approval of all molds manufactured for Stylemaster
or its predecessor in
interest. (Pl.'s Finding of Fact ¶ 18; Def.'s Finding of Fact ¶ 18.) Ms.Williams
approved the final samples of the Cost Reduction Molds in issue here.
specified by Ms. Williams
.In most instances, Ms. Williams
would submit design drawings and
Laverty would meet with Ms. Williams
As Ms. Williams
testified that Stylemaster
paid for repairs when the problems were
caused by Stylemaster
's faulty designs. (For example, Stylemaster designed one
mold with the wrong dimension on the stacking rib, (Williams Reopened Tr.
8/19/02 at 113-114.)) Ms. Williams
further testified that CME
or Cost Reductions
111. Sometime in 1999, Ms. Williams
designed a new product line referred to as the Contempra Line Molds. (Williams
Reopened Tr. 8/20/2004 at 63-65.) Ms. Williams
discussed the new product line
Tanner and Wenk, and also Ms. Williams
and Mr. Wenk testified
a letter to Ms. Williams
recommendations concerning Mold WX0200's
performance. (Def.'s Reopened Ex.43.) After receiving these documents, Ms.Williams
contacted Cost Reductions to make sure that Cost Reductions would pay
for all repairs relating to this mold.Ms. Williams
testified that she
believe the Mold was incapable of producing the parts Stylemaster required, butshe
was concerned about maintenance issues.
testified that although
Mold WX02000 had several defects, the mold was put into production and produced
over a million plastic products. (Williams Reopened Tr. 8/23/04 at 29-30.) After the defects were brought toMs. Williams'
continued to make payments for Mold
testified that Stylemaster
submitted inaccurate design information. (Williams
Reopened Tr. 8/19/02 at 114.) Stylemaster
, for example, designed
onemoldwiththewrongdimension on the stacking rib. (Williams Reopened Tr. 8/19/02
at 113-114.) CME
made changes to these molds at the request of Ms. Williams
(Pl.'s Reopened Ex.71 SMR 00762-00768.) Ms. Williams
accepted the molds after
corroborates Ms. Williams'
It must therefore be concluded, that
7/ Ms. Williams
testified that each
mold was put into production as fast as possible to enable the product to reach
8/ Ms. Williams
For instance, Ms. Williams
ofMr. Wenk who testified that Ms. Williams
to serve as
...principal's representative, Ms. Williams, contradictedMr.
A: I said if I were you, Martha
some of these, I would definitely reject these molds.
Q: Do you know if she
ever did that?
A: I know she
didn't do that.