Document YjNe8yVxYyb91O47KDBk4YVk0

FILE NAME Talc TALC DATE 2010 Aug 3 DOC TALC494 DOCUMENT DESCRIPTION Legal - Declaration of M. Baumgardner ofM Archive CRMC DECLARATION OF MARGARET J. BAUMGARDNER I Margaret J. Baumgardner declare 1 I am not a party to this action I have personal knowledge of the facts set forth in this declaration and if called as a witness I could and would competently testify as to the truth of the matters set forth herein 2. I am 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 createdin December 1998 andis 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 Facility which the from November 28 1988 the date on was consummated the Manville bankruptcy plan 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 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 assistedin the privilege review of documents to be given to the Trust From November 1988 to April 1994 I worked for Freeborn & Peters and was put in charge of the Facility managing all productions and new acquisitions In September 1995 I was hired by the Trust to manage the Facility In December 1998 I was hired by the CRMC to manage the Facility for the Trust Accordingly I am Declaration of Margaret J. Baumgardner Page 1 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 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 of the regularly conducted business activity of Manville and it was the regular practice and the business activity of Manville to make the records 6 Attached is a document found among the files and microfilm the Facility and are bates labeled 000001 through TALC- 000400 and these documents are true and correct copies of documents found at the Facility - I declare under penalty of perjury under the laws of the State of California and the State of Colorado that the foregoing is true and correct Executed on August 3rd 2010 in Aurora Colorado Margaret J. Baumgardner Subscribed and sworn to before me this 3rd day of August 2010 AMY BENHAM W FS q . NOTARY PUBLIC P STATE OF COLORADO My CommissionExpireMasy 16 2012 Declaration of Margaret J. Baumgardner . Page 2