Document kmD8Qjme0wNX4xe1zbRk12V0q

* JUSTIFICATION OF THE USE OF CftOCIDOLITE (BLUE ASBESTOS). IN THE MANUFACTURE OF ASBESTOS CEMENT CONDUIT FIFES The following technical major reason* justify the use of crocidolita for the manufacture of asbestos cement conduit pipes. ' 1. Filtrabillty.- ' The use of crocidollCe is necessary to obtain a better filtrabillty of the mixture# resulting la a reduction of the substantial loss of cement and thence# an improvement of productiveness. 2 . Resistance. - Only crocidolite can give the mixture the required * factors of mechanical strength. y. Unmouldlnq. - . As a consequence of the higher strength of the mixture# unmoulding Is quicker and easier. 4. Ovallratlon.- The Increased consistency of the mixture enables the pipe to keep its cylindrical shape# which is not die case with other types of asbestos fibre. 5. Flowing out.- ** Blue asbestos prevents the mixture from "running" ' over the machine# which adversely affects the winding up of layers on the mandrel. . Procedure.- . . The asbestos cement- pipes are manufactured along the Batschek procedure where the operations are performed in wet condition. As a consequence# these sequences do not free any asbestos dust. . Final product.- . Zn the final product# the asbestos fibres are completely caught in and locked-ln to the cement# as a result of the chemical reaction proceeding from its hardening. .En/DBJ/ADM 17 10.1977 . _1 at CRMC-SBGAB-ConduitPipe-000017 SC-GRAY-3310 AFFIDAVIT STATE OF COLORADO COUNTY OF ADAMS ) ) ss. ) I, Margaret J. Baumgardner, being of full age and first duly sworn do hereby state: 1. Iam not a party to this action. I have personal knowledge ofthe facts set forth in this affidavit, 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 created in December 1998 and is 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 the Facility from November 28, 1988, the date on which the Manville bankruptcy plan was consummated. 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 ofthe records which became the foundation documents for the Facility. I continued to work for Manville until September 1987. From March 1988 to September 1988,1 was hired to supervise and assist in the indexing ofthe first 20,000 boxes which were turned over to the Trust in November 1988. From September 1988 to January 1989, I assisted in the privilege review of documents to be given to the Trust. From November 1988 to April 1994,1 worked for Freeborn & Peters and was put in charge of the Facility, managing all productions and "new" acquisitions. In September 1995,1 was hired by the Trust to manage the Facility. In December 1998,1 was hired by Page 1 the CRMC to manage the Facility for the Trust. Accordingly, I am personally familiar with many of the records stored at the Facility, as well as how the records have been gathered. 5. To the best ofmy 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 ofthe regularly conducted business activity of Manville, and it was the regular practice and the business activity of Manville to make the records. 6. Attached are documents found among the file and microfilm box collections at the Facility. These documents, bates labeled CRMC-SBGAB-ConduitPipe-000001 through CRMCSBGAB-ConduitPipe-000092, are true and correct copies of documents found at the Facility. Subscribed and sworn to before me this 16th day of May, 2014. AMYWBENHAM NOTARY PUBLIC STATE OF COLORADO MY COMMISSION EXPIRES 05-23-2016 Page 2