Document 0qRv33M8dL8jBQpjL1MB9VrpV

5009 1103 JERRY DALE DAVIS, ET UX VS. ABLE SUPPLY, INC. ET. AL. PLAINTIFFS j EXHIBIT i BAR-372 NO. 26642 IN THE DISTRICT COURT MILAM COUNTY, TEXAS I 20TH JUDICIAL DISTRICT AFFIDAVIT OF W. A HEATH STATE OF TEXAS COUNTY OF HARRIS On this day, W. A. Heath personally appeared before me, the undersigned notary public, and after I administered an oath to him, upon his oath, he said: "My name is W. A. Heath. I am capable of making this affidavit and the facts stated in this affidavit are within my personal knowledge and are true and correct I am over 21 years of age. I have never been convicted of a felony and am competent in all respects to give the testimony contained in this affidavit I am the Manager of Records and Forms Management for Brown & Root, Inc., and have been so employed for twenty-six years. As such, 1 have access to all records of Brown A Root, Inc. processed and stored in accordance with the record retention policy of the corporation. The policy notwithstanding, Brown A Root has preserved contract documents from 1949 to the present. The Records Department currently has stored in excess of 70,000 boxes received from job site locations worldwide. My department also maintains documentation transferred to microfilm which includes the following quantities: Clinton Drive Facility 03-B14 35mm Engineering Drawings - 1,100,000 (Project Working Files) 16mm Roll microfilm - 300 Rolls (Active department rolls) 105mm Computer Output Microfiche - 2000 (Active Department Files) Alief Building 91 Concourse (Security film only) 35mm Engineering Drawings - 1,750,000 (Project Drawings and Marine Drawings 46657.1 Iftmm Computer Output film roll* * 11.000 {General Accounting, Payroll. Accaunu Pyihi Archive*) iUSnim Computer Output Miorofkhe - |*,SttU (Genas*! AccnuMtng.P'ayrwiS. Account* Payable ArAivni) Opijaur Syaiem CU-Kanu Cold (Conipuur Output In Uuct Uifc] - 2Su (Licnenl Accounting Huu>um and 1 anton. Payroil. fax Department* Henfiliii and lin^inc^ritij; Accounting) The (. oqxireic KccouU Center (CRT) detennnic* the appropriate rcicntum pcriuil lor each document type cu*cc on state ana federal regulation* ana catahtikhud iuuukwU *vm|ards. Several documents. including the Guide u record* Retention^ Requirement* published by the National Archives ft Records Service, provide the lautwkaoii fur cstubUdang rctenium period*, in addition, the enneanted dapunment manager. Tu Department. Legal Department. and the rennii Dfnui review inq approve the wiemOn pVm4i u naut* iha ilw ^tapoik cn meu all legal, departmental and client requirement* After an extensive and very thorough search nT the contract ducu-Ttcnu fur new cunstruetion. icpair and maintenance job*. we are unable to locale any job record* which reiled any wofit done by Brown it Pool for Uni versa! Zooomc Compuny Uniwraa) Zunomr Company, Michigan (1938-1967j Universal Zonoiite Company Universal Zottoiiu.- Company. Michigan (1947-195!j KmpiuycU by Sell Residence Michigan (19SU-iVbU) WkO i -2- wci'C^ i harriura. t the hea ii` my kAuUflelipi. baaed upon the la*& ui bppomnwc u] any reference* u< m>) of me above rcietcaced iM* la the Rewnh lifpmnmR it i< my helief that Brawn it ftam^id not participate' as*t*t nur d any work in connection with eny work uiatun la* aiihu*chot IV SWORN TO and SLUSCRlBl-X) hethre me b> W.A. Heath n the of V________ Notary Public in and fur the Suture; icA* LINDA S. ADKINS kxu)> *ubuc. sum * T*u LMauiiaa fjtutt io>ta>2oat ** 3- TOTfiL P.0S