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