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UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION Cp DORIS EIRVEN INDIVIDUALLY AND AS REPRESENTATIVE OF THE ESTATE OF ROBERT H. EIRVEN, DECEASED, ROBERT EIRVEN, JR. AND SHEILA EIRVEN, Plaintiffs, v. UNION CARBIDE CHEMICAL AND PLASTICS COMPANY, INC., Defendant AFFIDAVIT OF JOHN MACDONALD John Macdonald, being first duly sworn on oath, deposes and states as follows: 1. I am currently employed as the Assistant Corporate Secretary of Union Carbide Corporation ("UCC"). 2. UCC is a subscriber under the Texas Workers' Compensation Act and has been continuously since before 1955. 3. Robert Eirven was employed by UCC at its Texas City, Texas, plant from November 9, 1974, through January 22, 1991. During the entire time of his employment at UCC, Mr. Eirven was covered by workers' compensation insurance. Mr. Eirven never gave UCC written notice that he desired to retain his common law rights of action against UCC. FURTHER AFFIANT SAYETH NOT. John Macdonald Subscribed and sworn to before me this day of January, 1995. AKOnAB.POLVEMM Oowmtertangr c* DaaaB gstoofCOTcanii EXHIBIT A UCC 073557 nB UNITED STATES DISTRICT COURT FOR THE SOUTHERN HOUSTON DORIS EIRVEN INDIVIDUALLY AND AS REPRESENTATIVE OF THE ESTATE OF ROBERT H. EIRVEN, DECEASED, ROBERT EIRVEN, JR. AND SHEILA EIRVEN, Plaintiffs, v. UNION CARBIDE CHEMICAL AND PLASTICS COMPANY, INC. jjerendant. AFFIDAVIT OF JOHUT MCDONALD John McDonald, being first duly sworn on oath, deposes and state as follows; 1. I am currently employed as the Corporate Secretary of Union Carbide Corporation {"UCC"). 2. UCC is a subscriber under the Texas Workers' Compensation Act and has been continuously since before 1955. 3. Robert Eirven was employed by UCC at its Texas City, Texas plant from November 9, 1974 through January 22, 1991. During the entire time of his employment at UCC, Mr. Eirven was covered by workers' compensation insurance. Mr. Eirven never gave UCC written notice that he desired to retain his common law j.iyiiL <j otuLlvti ciyoij.ii.wL UCC. FURTHER AFFIANT SAYETH NOT. cp John McDonald Subscribed and sworn to before me this day of January 1995. EXHIBIT A UCC 073558