Document 7ODamGj29agLbpOqQgep5wJpV

FILE NAME: Shipbuilders Council of America (SHIP) DATE: 2014 Oct 23 DOC#: SHIP008 DOCUMENT DESCRIPTION: Legal - Affidavit of Margaret Baumgardner AFFIDAVIT STATE OF COLORADO ) ) ss. COUNTY OF ADAMS ) I, Margaret J. Baumgardner, being o f full age and first duly sworn do hereby state: 1. I am not a party to this action. I have personal knowledge o f the 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. Iam the Research Coordinator for the Claims Resolution Management Corporation ("CRM C"), a wholly owned subsidiary o f 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") o f Manville Corporation or related entities ("Manville"), generally, as well as Manville records relevant to litigation o f asbestos liability. The records found at the Facility were transferred from M anville to the Trust beginning in November 28, 1988, the date on which the Manville bankruptcy plan was consummated. Additional records have been and continue to be transferred directly to the Facility. The Facility's records have been in the custody and control of counsel for the Trust or Trust personnel since the date o f consummation. 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 o f the records which became the foundation documents for the Facility. I continued to work for Manville until September 1987. From M arch 1988 to September 1 9 8 8 ,1 was hired to supervise and assist in the indexing o f the 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 1994,1worked for Freeborn & Page 1 Peters and was put in charge o f the Facility, managing all productions and "new" acquisitions. In September 1995,1was hired by the Trust to manage the Facility. In December 1998,1was hired by 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 o f my 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 o f the regularly conducted business activity o f Manville, and it was the regular practice and the business activity o f Manville to make the records. 6. Attached are documents found among the file collections at the Facility. These documents, bates labeled CRMC-ShipbuildersCouncil-Files-000001 through CRMCShipbuildersCouncil-Files-000884, are true and correct copies o f documents found at the Facility. Subscribed and sworn to before me this 23rd day o f October, 2014. AMY W BENHAM NOTARY PUBLIC STATE OF COLORADO MY COMMISSION EXPIRES 05-23-2016 Page 2