Document jNgybKok8mgo99LaZBnYdkDaQ

Lj/'V ,V 1 DECLARATION OF JOHN L. MYERS 2 3 I, John L. Myers, declare as follows: 4 5 1. I have been employed by Union Carbide Corporation 6 ("Union Carbide") from 1951 to the present date, I have been 7 involved in the various aspects of Union Carbide's asbestos 8 operations since 1966, From 1970 to 1971, I held the position 9 of Marketing Manager-Asbestos of the Metals Division of 10 Union Carbide. As the Marketing Manager for asbestos, I was 11 involved on a daily basis with all phases of marketing asbestos 12 for Union Carbide. My responsibilities included marketing, 13 sales, technical services and the compilation of sales reports 14 for asbestos. As the Marketing Manager, I became familiar 15 with Union Carbide's sales of asbestos and asbestos-containing 16 material and the identity of entities purchasing Union Carbide's 17 asbestos material. 18 2. In 1981, I began to serve and am presently serving 19 as Product and Production Manager-Asbestos of the Metals Division. 20 I am responsible for and supervise Union Carbide's asbestos 21 ore mining and milling operations. As the manager of the 22 mining and milling operations, I receive and review reports 23 which inform me of the total production and shipments of 24 asbestos at the milling facility. 25 /// /// /// 7 83 PLAINTIFFS /// S EXHIBIT i UC-1418 1 3. My eighteen years in Union Carbide's asbestos 2 operation allow me to state that Union Carbide did not sell 3 any asbestos to Pioneer Flintkote in Los Angeles at any time 4 from 1946 to 1952, or to Flintkote in New Orleans, Louisiana, 5 at any time from 1946 to 1960. Not until 1963 .was Union 6 Carbide in the business of selling raw asbestos. Since 1963 7 Union Carbide has mined, milled and sold raw asbestos fibers 8 under the tradename CALIDRIA, Because CALIDRIA was not 9 marketed until 1963, Union Carbide could not have sold any 10 CALIDRIA asbestos to Pioneer Flintkote at any location during 11 the years 1946 to 1960. 12 I declare under penalty of perjury that the 13 foregoing facts are true and correct and that this declaration 14 was executed on ., 1984, at 15 King City, California. 16 3.7 18 19 John L. Myers 20 21 22 23 24 25 26 27 ii Ii Qo /4 28 Crutcher 2