Photocopy

STATE OF GEORGIA	}
	}	................AFFIDAVIT
COUNTRY OF MUSCOGEE	}

Before me, the undersigned authority, this day appeared Donald R. Black, known to me by creditable photographic identification to be the same person as the deponent herein, who, being by me duly sworn deposed and stated:

"My name is Donald R. Black. I was employed by Aerospatiale Helicopter Corporation at Grand Prairie, Texas, as Human Resources Manager (historically known as Personnel Manager) at all times pertinent to the following listed facts:

1. Ron Carbone and Larry McNeill came to me on several occasions regarding terminating Robert C. Ballew from his position as a Purchasing Agent for Aerospatiale Helicopter Corporation of Grand Prairie, Texas.
2. Their specific and stated intent was to terminate Ballew.
3. The decision to terminate Ballew had been made by them and the only remaining problem was to plan and enact the most plausible and legally defendable action to accomplish this termination.
4. Ballew's termination was meant to remove him from any future involvement with the AHC / United States Coast Guard "Short Range Recovery Helicopter" contract and sub-contract problems and more specifically to get rid of him completely.
5. It was decided that initially Ballew was to be isolated from both the work he had been performing and the files that pertained to it. This was to be accomplished by assigning him to another of Carbone's direct employees which at that time was the AHC attorney, Ms. Rene Martin Nagle. He was to be placed on a menial work project at a task remote in space and purpose from his normal duties and fellow employees.
6. Ballew's actual termination was to be accomplished by the elimination of his job description or position. The remaining work was to be reassigned to a temporary consultant who had been hired during Ballew's illness. The requirement for the positions work was not completed and it was assigned to Mr. Kenneth Taylor. After Ballew's termination, Mr. Taylor became a permanent employee of AHC performing the same basic work that Mr. Ballew had been performing at the time of his termination.
7. Lois Smithey had less seniority than Ballew and for that reason only was terminated on the same day as Ballew. It was decided that she must also be terminated to add credibility to the termination of Mr. Ballew.
8. This action made both job eliminations appear to have been performed by "Seniority". Lois Smithey's termination was a direct result and she was a casualty of the company's desire to terminate Ballew. The work requirement was still present and both Ballew's and Smithey's work was reassigned to a specially hired consultant and other AHC employees.
9. Lois Smithey's termination was added to conceal and disguise the primary intention of Ballew's dismissal as related to me by Ron Carbone, who ordered it done."

In attestation to which I place my hand under oath this 14th day of January, 1992.

___(Signature)___
Donald. R. Black

Sworn and subscribed before me this 14th day of January, 1992.