Document 0J2akqR361z3jEREwqQj79e6k

/ TO ALL FtTER PRODUCTS AND ~*IN D U-S--T-R--I_A___L_____D_ ISTR____I_C_ _T liANAGSRS -. ALL BUILDING MATERIAL UAHAOERS GENERAL EZ^J)QUARTERS April 7. 1937 SUPERVISOR! LETTER #120 AUERIC&N TELEPHONE AND T&BQRAPI1 COBPAN! AND ASSOCIATED OOUPAHIES TRANSIT! CONDUIT AND TRANSITS KORDUCT Undsr date of Baroh 17th, the Assistant Chief Ffrglneer of the Amerioan Telephone end Telegraph Company forwarded the approval of Transit# Conduit and Tranelte Xorduet to all chief engineer* of Aeeoolated Companies, This approval went out with P.E.L. (Plant Engineering Letter) #2693* and. P.E.L. (Plant Engineering lfsoorandum) #913,j A number of oopiee of this letter and memoranda were sent to the Chief Engineers of Assoolated Companies with ooples of our Conduit broohure. This is the sane list of Chief Engineers sent you by lir. T, E. ilial, under date of August 20th, 1936. It-is a ooanton practioe with these Chief fiigineers to re view such data and then forward it to Division and District Engineers and to Outside Plant Engineers in the Assoolated Companies, A list of the Outside Plant Engineers of Assoolated Companies are attached hereto* host of these Assoolated Conpanles are broken down into divisions and districts and in each division there are corresponding Outside Plant Engineers who report to the Headquarters aen shown on this list* In each district there is, in turn, an. Outside Plant Engineer who reports to his division Outside Plant Engineer, Parallel to this Outside Plant Engineering Department, there are representatives of the Chief Engineer in each Division and District of each Associated Company. These Distrlot and Division Engineers and Outside Plant Engineers are the keymen whom we must contact and sell on the use of our product. The question of the corrosion of lead sheathed cable due to the alkalinity of our duet, is answered in the memorandum. It states that improvements in methods of manufacture have reduced the alkalinity of our duct to the point where it is not dangerous providing hare is exeroised in the Installation of the duot so that all duct will drain properly. This caution is in no way restrictive because all companies, both telephone and power, recognise the neoesslty of proper drainage of all types of Conduit, In this memoranda is an scaaple of the price at which our products sell. Obviously, they were not interested in reproducing our entire tone price schedule, therefore they showed our C quantity. Zone 3 prioes, for 2, 3 and . 3i* Conduit and Korduot which are the sisss they will be particularly inter ested in. It will be neoessary for our men to oontaot all of the fiigineers as indicated above, deliver a copy of our Prioe Sohedule to then, and be sure that they understand that the prioes shown in their company's asmorandum are among the highest prioss shown In our Prioe schedule, and that the actual price ef the material delivered may be very materially lower than the prices given thsm, depending entirely upon quantity and location of Job, This A, T, A T, approval does not mean that the Associated Companies will automatically start to use our oonduit. It merely gives them permission to use it if they see fit, Ve have the ssme Job of selling this organisation that we have in selling the local men ef all power companies, */e must build Just as eloss a relationship with their Outside Plant Engineers and repre sentative of Chief Engineer's Department as ws now have with the underground distribution msn in power companies. IT// *? /) si.'** CRMC-SBGAB-ConduitPipe-000031 SC-GRAY-0111  Page 2* Our first entry in this field should be on ell jobs where they normally would use steel oonduit, either underground or in exposed locations, where mechanical strength is not the prime factor* In the above mentioned memorandum* the possibility of our material supplanting steel oonduit is specifically men tioned* In this case we have a decided price advantage and other superior qualities* suoh as freedom from corrosion, electrolysis, galvanic action,etc. Ve 41reedy have a number of jobs of this nature with telephone interests, not able asKDg which are installations on bridges, particularly at Fargo* Uorth Dakota* and at Indianapolis, Indiana* One of these is an exposed job where weight* freedom from corrosion and prloe are factors, In the other * It is an enoased job where weight and freedom from oorroslon and eleotrolysls were fac tors* The next most likely application is where they would normally use pump log (creosoted wood duct). This material, on the average, is slightly lower in price than our duot* but there are many locations where it will not endure the soil conditions encountered. Our duct is lighter in weight, much easier to handle* makes up a better joint, and, of course, has decided advantages from the life expectancy standpoint. The next most likely application is where they now use single runs of clay tile. 'Jhile the first oost of single clay tile is less than ours* it is made only in very short lengths and the joints are very hard to make up to any de gree of satisfaction* Tills company is also using some special araored cables* Here we have the same argument that we have on street lighting and fire alarm jobs, namely, that our duot with an ordinary cable frequently costs no more than the special cable. '/e should be able to secure a very attractive amount of business for the loca tions where the above types of duot are used* r.'e cannot hope to get their main duct line business because in telephone work multiple clay tile is entirely satisfactory and it oan be Installed at a much lower prloe per duct-foot than either Transite Conduit or Korduot. MU you please see that all of the men on the attached lists are contacted promptly? If the above referred to letter has not.yet reached them, our men can refer to the nisnber thereof so that these engineers will be on the look out for it* 're should ascertain the division and dlstriot organisation set-up of each associated company* and learn the names of the Outside Plant Engineers and Chief Engineer's Representatives in each division and district and then contact them* A few calls along these lines will indicate to our salesmen what further oontact should be made* This finally officially opens up a very fine market for Conduit and possibly a wll market for hordact* The metropolitan Dlstriot have done a fine job on following through on this and if all of our dlstriot field organisations do an equally good job* we will reap very fine returns from the. efforts* attached is a copy of a bulletin going to all salesmen* OUT* A* BARTER CRMC-SBGAB-ConduitPipe-000032 AFFIDAVIT STATE OF COLORADO COUNTY OF ADAMS ) ) ss. ) I, Margaret J. Baumgardner, being of full age and first duly sworn do hereby state: 1. Iam not a party to this action. I have personal knowledge ofthe facts set forth in this affidavit, and if called as a witness, I could and would competently testify as to the truth of the matters set forth herein. 2. I am the Research Coordinator for the Claims Resolution Management Corporation ("CRMC"), a wholly owned subsidiary of the Manville Personal Injury Settlement Trust ("Trust"). The CRMC was created in December 1998 and is staffed by former Trust employees. On January 1, 1999, CRMC began providing claims resolution facility services to the Trust. 3. In this position, I manage the Asbestos Claims Research Facility ("Facility"), a document and records repository located at 3390 Peoria Street, Suite 304, Aurora, Colorado. The Facility contains the business records including but not limited to correspondence, memoranda, reports, records and data compilations ("record") of Manville Corporation or related entities ("Manville"), generally, as well as Manville records relevant to litigation of asbestos liability. The Trust has managed and operated the Facility from November 28, 1988, the date on which the Manville bankruptcy plan was consummated. 4. My experience and familiarity with the documents at the Facility began in 1983 while working for Manville. In my work as a paralegal for Manville, I assisted in locating, indexing and packing many ofthe records which became the foundation documents for the Facility. I continued to work for Manville until September 1987. From March 1988 to September 1988,1 was hired to supervise and assist in the indexing ofthe first 20,000 boxes which were turned over to the Trust in November 1988. From September 1988 to January 1989, I assisted in the privilege review of documents to be given to the Trust. From November 1988 to April 1994,1 worked for Freeborn & Peters and was put in charge of the Facility, managing all productions and "new" acquisitions. In September 1995,1 was hired by the Trust to manage the Facility. In December 1998,1 was hired by Page 1 the CRMC to manage the Facility for the Trust. Accordingly, I am personally familiar with many of the records stored at the Facility, as well as how the records have been gathered. 5. To the best ofmy knowledge, information and belief, I certify that these records were made at or near the time by, or from information transmitted by, a person with knowledge, were kept in the course ofthe regularly conducted business activity of Manville, and it was the regular practice and the business activity of Manville to make the records. 6. Attached are documents found among the file and microfilm box collections at the Facility. These documents, bates labeled CRMC-SBGAB-ConduitPipe-000001 through CRMCSBGAB-ConduitPipe-000092, are true and correct copies of documents found at the Facility. Subscribed and sworn to before me this 16th day of May, 2014. AMYWBENHAM NOTARY PUBLIC STATE OF COLORADO MY COMMISSION EXPIRES 05-23-2016 Page 2