Document 1QJRmVKa9grQJyQ5Kgj6gdkq5

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS ^ DEFENDANTS DEPOSITION EXfHi_IBI,T ALICE L. WARREN, ADMINISTRATRIX OF THE ESTATE OF JOHN H. WARREN, DECEASED, Plaintiff, v. THE DOW CHEMICAL COMPANY, THE B.F. GOODRICH COMPANY, WHITTAKER DEVELOPMENT CO. (FORMERLY GREAT AMERICAN CHEMICAL CORPORATION), UNION CARBIDE COMPANY, AMERICAN CYANAMID CORPORATION, AND CONTINENTAL OIL COMPANY, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) C.A. No. 89-30201-F NOTICE OF TAKING DEPOSITION To: Lane McGovern, Esq. Pierce O. Cray, Esq. Ropes & Gray One International Place Boston, MA 02110 James H. Tourtelotte, Esq. Robinson, Donovan, Madden & Barry, P.C. 1500 Main St., Suite 1400 Springfield, MA 01115 PLEASE TAKE NOTICE that, pursuant to the provisions of Fed.R.Civ.P., Rule 30, The B.F. Goodrich Company (*BFG*), a defendant in the captioned action, will, by its attorneys, Morrison, Mahoney & Miller, take the deposition upon oral examination of Ruth Griffith, at the offices of Morrison, Mahoney & Miller, 1145 Main Street, Springfield, Massachusetts, at 10:00 AM on Wednesday, May 9, 1990 before an officer authorized by law to administer oaths. The oral examination will continue from day to day until completed. The deponent is required to bring to the deposition the following documents: 1. Any and all records of shipment or receipt of vinyl chloride from any entity at the Monsanto facilities in the Springfield area during the years 1947-1983. 2. Any and all notes, papers, books and other writings relating to the shipment, receipt, use, storage or disposal of vinyl chloride at the Monsanto facilities in Springfield during the years 1947-1983. 3. Any and all photographs or drawings that depict the shipment, receipt, use, storage or disposal of vinyl chloride at the Monsanto facilities in Springfield during the years 1947-1983 4. Any and all notes, drawings, papers, books and other writings relating to the operation of the Monsanto facilities in the Springfield area during the years 1947-1983 5. Any and all notes, drawings, photographs, papers, books and other writings relating to or written by John H. Warren. 6. Any and all photographs, drawings, papers, notes, books, and other writings relating to the exposure of workers at the Monsanto facilities in the Springfield area to vinyl chloride during the years 1947-1983 7. Any and all photographs, drawings, papers, records, notes, books and other writings relating to or identifying the names and addresses of suppliers of vinyl chloride to Monsanto facilities in the Springfield area during the years 1947-1983 You are invited to attend and cross-examine. Date: i cen-.fv that this document has been served upon ail ;c'Jr,sei/;t teoord imcomDliance with the F.R.C.P. / //#? L ,t21 Mark S. Granger Joseph E. Rendini Morrison, Mahoney & Miller Attorneys for Defendant B.F. Goodrich Company 250 Summer Street Boston, MA 02210 (617) 439-7500 2 G G'$ 6