Document K6Od8Np3xr3K4Zb4v48rpg7ON

c O ^N F I D E N T I A L Johns-Manviiie internal Correspondence R. Trude11 Don. February 5, 1976 lagee G. . Sloan, File, Chrono GENERAL ELECTRIC COCHICAGO HEIGHTS, ILLINOIS TRANSITS TRAYS IN' PIZZA OVENS A Mr. Earl Spillar (312-757-5000) of G. E. asked Jim Reis about the asbestos health hazard implication of using Transite for the baking decks on pizza ovens. G.E. has been making these Transite ovens for many years. The pizza comes in direct contact with the surface of the Transite during the baking. Reis told Spillard he would get the official J-M position on this. He phoned Ed Fenner who said that although there was no real evidence of a health problem, we (J~M) would not recommend that it be used as pizza trays. Sensing th e marketing implications of this position, Reis contacted me and requested that I talk to Mr. Spillar. I discussed the matter again with Ed Fenner, pointing out that Trans ite was used widely for pizza trays and that if we told G. E. not to use it, we would have an obligation to so inform other.manufacturers also. This could trigger off tremendou wave of popular reaction inasmuch as there are thousands of Transite pizza ovens in service. I told Ed,that in my.judgment, if the use of Transite in the pizza oven was a proven, health threat, J-M had a moral obli gation to speak out. In view of the circumstances he modified his position and tola me he felt our moral obligation would be fulfilled if we toJc' G.E. that there is no evidence of an asbestos health problem relating to the use of Transite. in pizza ovens. I ononed Mr. Soillar at G.E. and cave him this information. JVM:s s SC-GE-06440 MT-LIP-000878 STATE OF COLORADO COUNTY OF JEFFERSON AFFIDAVIT ) ) ss. ) I, Margaret J. Baumgardner, being of full age and first duly sword do hereby state: 1. Iam the Research Coordinator for the Claims Resolution Management Corporation ("CRMC"), a wholly owned subsidiary of 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. 2. In this position, I manage the Asbestos Claims Research Facility ("Facility"), a document and records repository located at 4755 East 46th Avenue, Denver, 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. \ 3. My experience and familiarity with the documents at the Facility began in 1983 while irking for Manville. In my work as a paralegal for Manville, I assisted in locating, indexing and packing many ofthe records which became the foundation documents for the Facility. I continued to work for Manville until September 1987. From March 1988 to September 1988, I 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. 4. To the best of 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 ofthe regularly conducted business activity ofManville, and it was the regular practice and the business activity of Manville to make the records. Margaret J. Baumgardner Affidavit Page 2 5. Documents from this Facility were copied for the law firm ofDavid M. Lipman, P.C. The copies have come from microfilm and boxes at the Facility and are bates labeled MT-LEP000001 through MT-LIP-001280 and these documents are true and correct copies of documents found at the Facility. Subscribed and sworn to before me this 6th day of June, 2006.