Document 3Jd4eGj1DwO72L5QjzpZQgqg0

CAUSE NO. 99-C-582 ROBERT RANDALL GOSS, Individually and as Personal Representative of the Heirs and Estate of MILDRED ANN GOSS, Deceased vs. ABLE SUPPLY CO., ET AL IN THE DISTRICT COURT CASS COUNTY, TEXAS 5th JUDICIAL DISTRICT AFFIDAVIT OF W.A. HEATH STATE OF TEXAS COUNTY OF CASS On tins day, WA 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 ofmaking 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 ofa felony and an competent in all resects to give the testimony contained in this affidavit I am the Manager ofRecords and Forms Management for Brown & Root Inc., and have been employed for twenty-six years. As such, I have access to all records of Brown & Root Inc. processed and stored in accordance with the record retention policy of the corporation. The policy notwithstanding, Brown &. 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-bl4 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) AliefBuilding 91 Concourse (Security film only) 35mm Engineering Drawings - 1,750,000 (Project Drawings and Marine Drawings Archived) AFETDAYIT OF W.A. HEATH S:\ASBESTOS\19308\3626\AFFIDAVT.WPD Page-1- Ifimm Microfilm Rolls * 22,000 (Departmental and Project Files Archived) 1 fimm Computer Output film rolls 11,000 (Genera] Accounting, Payroll, Accounts Payable Archives) 105mm Computer Output Microfiche - 18,500 (General Accounting, Payroll, Accounts Payable Archives) Optistar System CD-Roms cold (Computer Output to Laser Disk) - 250 (General Accounting Houston and London, Payroll, Tax Department Benefits and Engineering Accounting The Corporate Records Center (CRC) determine the appropriate retention period for each document type based on state and federal regulations and established national standards. Several documents, including the Guide to Records Retention Requirements published by the National Archives & Records Service, provide the foundation or establishing retention periods. In addition, the concerned department manager. Tax Department, Legal Department, and the records officer review and approve die retention periods to endure that the company can meet all legal, departmental and client requirements. After an extensive and very thorough search ofdie contract documents for new construction, repair and maintenance jobs, we are unable to locate any job records which reflect any work done by Brown & Root for the following sites: Owens Illinois Glass Plant, Waco, Texas (1953*1970) Therefore, to the best ofmy knowledge, based upon the lack ofappearance ofany referenced to any ofdie above referenced sites in the Records Department, it is my beliefthat Brown St Root did not participate, assist nor do any work in connection with any work occurring at those above listed sites. 1 LUCINDA H. DE LA GARZA | Niurr Mile. Sim tl Tmi j l of Texas AFFIDAVIT OF W.A. HEAjp S:\ASBESTOS\19308\3626\AFFIDAVT.WPn Page-2-