Document BvGXqG6B682KNzrxn4xnmZgrk

AFFIDAVIT STATE OF COLORADO COUNTY OF ADAMS ) ) ss. ) I, Margaret J. Baumgardner, being of full age and first duly sworn do hereby state: 1. Iam not a party to this action. I have personal knowledge ofthe 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 ("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. 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") of Manville Corporation or related entities ("Manville"), generally, as well as Manville records relevant to litigation of asbestos liability. The Trust has managed and operated the Facility from November 28, 1988, the date on which the Manville bankruptcy plan was consummated. 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 of the records which became the foundation documents for the Facility. I continued to work for Manville until September 1987. From March 1988 to September 1988,1 was hired to supervise and assist in the indexing of 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 1994,1 worked for Freeborn & Peters and was put in charge of the Facility, managing all productions and "new" acquisitions. In September 1995,1 was hired by the Trust to manage the Facility. In December 1998,1 was 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 ofmy 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 ofthe regularly conducted business activity ofManville, and it was the regular practice and the business activity of Manville to make the records. 6. Documents from this Facility were copied for the firm of Simmons, Browder, Gianaris, Angelides & Bamerd. The copies have come from files at the Facility and are bates labeled CRMC-Thermo&Cement-OOOOOl through CRMC-Thermo&Cement-000105 and these documents are true and correct copies of documents found at the Facility. Subs j/ibed and sworn to before s 15th day of November, 2011. faryfPublic AMY W BENHAM I NOTARY PUBLIC I STATE OF COLORADO _J My Commission Expires May 16,2012