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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

STATE

NOIf

OF

2 6 2003

PEOPLE OF THE STATE OF ILLINOIS,

)

pollution ~

Complainant,

)

)

v.

)

PCBNo.03-22

)

(Enforcement)

SAINT-GOBAIN CONTAINERS, INC.,

)

a Delaware corporation,

)

)

Respondent.

)

AFFIDAVIT OF WRAY C. HISER

Wray

C.

Hiser, being first duly sworn, deposes and states as follows:

1.

I

am Associate General Counsel for Saint-Gobain Containers, Inc.

2.

Saint-Gobain Containers, Inc., is a wholly-owned subsidiary ofSaint-

Gobain Corporation, a holding company for the American businesses ofthe French

parent company, Compagnie de Saint-Gobain. As such, Saint-Gobain Containers, Inc.

does not prepare any type ofreports or filing regarding its financial information.

3.

The financial information about Saint-Gobain Containers, Inc. contained

on the two page unaudited financial statement at issue for the Motion for Protective Order

is considered extremely confidential by the Company. It is only provided to employees

ofthe Company that must have access to the information to perform their duties.

Respondent’s unaudited financial information is not made public in any way.

4.

Any disclosure of this confidential financial information could be

detrimental to the Company in a number of ways, such as providing beneficial

information to our competitors about the financial strength and profitability of this

Company, to labor unions representing our hourly workforce in union contract

---

negotiations, or to our customers and suppliers in negotiating supply contracts with our

Company.

5.

Disclosure ofthis sensitive unaudited financial information to parties

outside ofthis litigation would be detrimental to Respondent’s business interests.

6.

I have reviewed Saint-Gobain Containers, Inc.’s Reply To Complainant’s

Response In Opposition to Respondent’s Motion for Protective Order.

7.

The matters set forth in Saint-Gobain Containers, Inc.’s Reply To

Complainant’s Response In Opposition to Respondent’s Motion for Protective Order are

true and correct to the best of my knowledge and belief.

8.

The statements made in this affidavit are true and correct to the best ofmy

knowledge and belief.

FURTHER AFFIANT SAYETH NOT.

Wra

.

Hiser

Subscrib~and sworn to before me

this

~

‘~

day of November 2003.

Notary Public