Sworn statement by non-managerial employee of defendant

SWORN STATEMENT OF

STATE OF TEXAS §

§

COUNTY OF _______ §

On this day _____ personally appeared before me, who being personally known to me, upon [his/her] oath did state as follows:

"My name is _____. I swear and affirm that all statements made in this Affidavit are within my personal knowledge true and correct."

"Prior to discussing any matters regarding _____, my [current/former] employer (hereafter "my employer"), _____ informed me that [he/she] was the attorney for _____ and that [he/she] was investigating _____’s (hereafter "the claimant") potential claims against my employer."

"Also, before discussing any substantive matters, _____ explained to me that [he/she] wanted to interview me and take a statement as part of _____'s investigation of the claimant's claims against my employer. _____ informed me that [his/her] investigation and this interview might reveal facts that would indicate the claimant should sue and might sue my employer."

"Before I discussed any substantive matters with _____ or signed any statements, [he/she] asked me what job I had with my employer. I informed [him/her] that I had [not been/was not] an officer, managing employee, or person with managerial responsibility with my...