Document 5LEL3EL65wkZV6d124RQ4wXYz
AFFIDAVIT
PLAINTIFF'S EXHIBIT JM-2405
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STATE OF COLORADO COUNTY OF JEFFERSON
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I, Margaret J. Baumgardner, being offull age and first duly sworn do hereby state:
1. I am an Information Processing Coordinator for the Claims Resolution Management Corporation ("CRMC"), a wholly owned subsidiary ofthe 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.
2. In that position, I manage . Records Repository which is located at 11000 East 51 st Avenue, Denver, Colorado.
3. The Repository contains documents obtained from Manville Corporation and related entities which relate to asbestos litigation. The Trust managed and operated the Repository from November 28, 1988, the date on which the Manville bankruptcy plan was consummated.
4. Documents from this Repository were copied for the law firm of Baron & Budd relating to the fiber content ofJohns-Manville Corporation's roofing shingles and siding. The copies have been bates labeled as numbers MT-000047 to MT-000566, and these documents are true and correct copies of documents found at the Repository.
Further affiant sayeth not.
J. 4
Marg&ret J. Baumgardner
Subscribed and sworn to before me this 4th day of December, 2000.
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