Document 2RbkoZQ3z9JpLVVyrgaZZrxdL

niinn o r S itt ofMaine C unity ofCumberland ) ) ) ]; Gc iard J. Horan, Jr., being duly sworn, stats under oath: ]. I :ixa a naval architect and a member ofthe Society ofNaval Architects and Maxine Eginecrs. One ofmy areas ofexpertise is research on ship design, construction and repair, shipbuilding practices and other issues related to Navy shipbuilding and repair. 2. During the 1940s, manufacturers ofhigh temperature insulating products for thermal pioe covering, insulating block and insulating cement were required to have their respective products undergo testing and approval by the Navy prior to use aboard U.;5. Naval combatant vessels, built or overhauled at US Naval Shipyards, including th<: Brooklyn. Navy Yard. The approved manufacturers were listed on the Navy Approved Material Li;3s. . 3 t h.rve personally reviewed Approved Material Lists for thermal pipe covering, he tmal insulating block, and high temperature insulating cement dated from the late iSWO's through the 1940's. 4. vtundet Cork Corporation was not listed as an approved manufacturer ofthermal pipe overing, thermal Insulating block, or high temperature insulating cement during this lexiod. . - ' Svfi\ n v.o me, this third day ofJanuary, 2000.