Document YjkOMBmaJkwBKZ7DRy0vBj67N
PLAINTIFFS EXHIBIT
WH-996
AFFIDAVIT
PARISH OF ORLEANS
STATE OF LOUISIANA
BEFORE ME, the undersigned authority, personally came and appeared:
JAMES CARROLL
who after being duly sworn did depose and say:
1. I was employed by Avondale from 1945 to 1988.
2. That while employed at Avondale, I was employed as a burner, shipfitter. leader man, and retired as an assistant superintendent.
3. That during the course of my employment, I worked on all commercial ships being built at Avondale.
4. During the course of my work, I worked around Hopeman Brothers.
5. That I recall dust being created in the area where I worked when working around Hopeman Brothers.
6. That if dust was created by Hopeman Brothers, I was exposed due to the proximity in which I worked near Hopeman Brothers.
SWORN TO AND SUBSCRIBED TO BEFORE ME THIS_______ DAY OF
, 1997.
JAMES CARROLL
NOTARY PUBLIC