Document EmD5gL5J0p36z8D3RZ0mQqNdx

05009.00027/jks IMOGENS HARJUSON, et. al. v. NO. 97D8115 < IN THE DISTRICT COURT S TRAVIS COUNTY, TEXAS ABLE SUPPLY CO., ET. AL. 98TH JUDICIAL DISTRICT AFFIDAVIT OF W. A. HEATH STATE OF TEXAS COUNTY OF HARRIS S On this day, W. A. 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 of making this affidavit and the facts stated in this affidavit are within my personal knowledge and are one and correct. 1 am over 21 years of age. I have never been convicted of a felony and am compete* in all respects to give the testimony wwd in this affidavit. I am the Manager of Records and Farms Management for Brown & Root, Inc., and have been so employed for twenty-four years. As such, I have access to all records of Brown Sc Root, Inc. processed and stored in accordance with die record mention policy of die 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-B14 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) Alief Building 91 Concourse (Security film only) 35mm Engineering Drawings - 1,750,000 (Project Drawings and Maxine Drawings Archived) 16mm Microfilm Rolls - 22,000 (Departmental and Project Files Archived) ml W.A. M - *mmm 1 I6ma Computer Output film tolls - 11,000 (General Accounting. Payroll, Accounts Payable Archives) 105mm Computer Output Microfiche - 18,500 (General Accounting, Payroll. Accounts Payable Archives) Optinar System CD-Roxns Cold (Computer Output to Laser Dish) - 250 (General Accounting Houston and London, Payroll. Tax Departments Benefits and Engineering Accounting) The Corporate Records Center (CRO determines the appropriate retention period for each document type based on state and federal regulations and established national standards. Several documents, including the Ouide to records Retention Requirements published tty the National Archives & Records Service, provide die foundation for establishing retention periods. In addition, the the concerned department manager. Tax Department. Legal Department, and die records officer review and approve the retention periods to ensure that the company can meet all legal, departmental and client requirements. After an extensive and very thorough search of the contract documents for new construction, repair and maintenance jobs, we are usable to locate any job records which reflect any work done by Brown & Root at Lubbock Power A Light in Lubbock. TX during the yean 1960-1986. Thgcfoie, to the best of my knowledge, based upon the lack of appearance of any references to Brown A Root at Lubbock Power A Light in Lubbock. TX during the yean 19601986. in the Records Department, it is my belief that Brown & Root did not participate, assist or do any work in connection with any work occurring by Brown & Root at Lubbock Power A Light in Lubbock. TX during the yean 1960-1986. SWORN TO and SUBSCRIBED before me by W.A. Heath on the Odb&u, 19 . day of the State of Texas Affidavit oT WA. Htath fat 2