Document mbdO0QOV6N5Z8j0kyrbLj4wrZ
FILE NAME: NIN DATE: 2000 Mar 28 DOC#: NIN001 DOCUMENT DESCRIPTION: Documant Affidavit with Cover Letter
C laims R esolution M anagement C o r po r a t io n
A subsidiary of MANVILLE PERSONAL INJURY SETTLEMENT TRUST
VIA FEDERAL EXPRESS
Margaret J. Baumgardner Information ProcessingCoordinator
March 28, 2000
John N. Lipsitz
Lipsitz & Ponterio, LLC
135 Delaware Avenue, Suite 506
,
Buffalo, NY 14202
Re: Documents from Repository
Dear Mr. Lipsitz:
Enclosed is the affidavit with the documents you requested. I have also included a copy o f my first letter to you with a copy of the information packet, if you need a copy o f the order mentioned in the agreement, please contact me and I will forward one to you. If you have any questions or need additional research, please do not hesitate to contact me.
Sincerely,
Margaret J. Baumgardner Enclosures
Warehouse 11000 East 51st Avenue
Denver, Colorado 80239
Phone: (303) 576-9620 Fax: (303) 576-9624
Main Office 8260 Willow Oaks Corporate Drive
Suite 600 P.O. Box 10415 Fairfax, Virginia
22031 Phone: (703) 204-9300
P*v. n m \ one / r u n
AFFIDAVIT
STATE OF COLORADO COUNTY OF JEFFERSON
) ) ss. )
I, Margaret J. Baumgardner, being o f full age and first duly sworn do hereby state:
1. I am an Information Processing Coordinator for the Claims Resolution Management Corporation ("CRMC"), a wholly owned subsidiary o fthe 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.
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2. In that position, I manage a Records Repository which is located at 11000 East 51 st
Avenue, Denver, Colorado.
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3.
The Repository contains documents obtained from Manville Corporation and related
entities which relate to asbestos litigation. The Trust managed and operated the Repository from
November 28,1988, the date on which the Manville bankruptcy plan was consummated.
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4. Documents from this Repository were copied for the law firm o f Lipsitz & Ponterio These documents: a two page letter from R.C. Braun o f Niagara Asbestos Company, Inc. to JohnsManville Sales Corpation dated May 4, 1960 and a two page letter from Jack M. Lovell o f Safety Management Company, Inc. to Ray C. Braun o f Niagara Asbestos, Inc. dated April 29,1960 are true and correct copies o f documents found at the Repository.
Further affiant sayeth not.
"T. MargarlSet JJ. Baumgardner 8 a^:..
Subscribed and sworn to before me this 28th day o f March, 2000.
.i
Notary Public (J
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