Document Na5KBwELba8K2J2rkQLGDR0y

CRMC-Talc-Micro-004874 CRMC-Talc-Micro-004875 n r 4 4-14 TtJfTP ! `~ r r CRMC-T alc-Micro-004876 `\SOti. t $ it S .tt.lM m e r CRMC-T alc-Micro-004877 CRMC-T alc-Micro-004878 CRMC-T alc-Micro-004879 CRMC-Talc-Micro-004880 \Ost. isr l.s> L*wM<r CRMC-Talc-M icro-004881 AFFIDAVIT I, Margaret J. Baumgardner, being o f full age and first duly sworn do hereby state: 1. Iam 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. Ia m the Research Coordinator for the Claims Resolution Management Corporation ("CRMC"), 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 Manville 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 of 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 March 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 & 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 Affidavit o f Margaret J. Baumgardner Page 1 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 of my knowledge, information and belief, or from information transmitted by a person with knowledge, I certify that these records were made at or near the date they are identified, 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 microfilm collections at the Facility. These documents, bates labeled CRMC-Talc-Micro-000001 through CRMC-Tulc-Micro-005259, are true and correct copies of documents found at the Facility. STATE OF COLORADO COUNTY OF ARAPAHOE ) ) ss. ) Subscribed and sworn to before me this 27th day o f January, 2017. AMYWBNHAM NOTARY PUBLIC 8TATE OF COLORADO NOTARY 20064017385 MYCOMMISSION EXPIRESMAY23,2020 Affidavit o f Margaret J. Baumgardner Page 2