Document zon22QZya0O1r9xdZYe0K7Ja3
AFFIDAVIT
STATE OF COLORADO COUNTY OF JEFFERSON
) ) ss. )
I, Margaret J. Baumgardner, being of 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 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.
2. In that position, I manage a Records Repository which is located at 11000 East 51 st Avenue, Denver, Colorado.
3. The Repository contains documents obtained fromManville Corporation and related entities which relate to asbestos litigation. The Trust has managed and operated the Repository from November 28, 1988, the date on which the Manville bankruptcy plan was consummated. These records are maintained at the Repository in its regular course of business.
4. Documents fromthis Repository were copied for the Simmons Firm after their review ofJanuary 14* and 15*,2001. The copies have been bates labeled as numbers MTS000001 to MTS12052, and these documents are true and correct copies of documents found at the Repository.
Further affiant sayeth not.
A
J. Baumgardner
Subscribed and sworn to before me this 28* day of January, 2002.
My ranraissta Bpres Nwentoer 15,2002 u 4350Waiferaft Boulevard
Wheat Ridge Colorado 80033