Document 1gmMk3yYkkd0eBjB0z3Rj5zDd

WILLIAM E. SWIFT KENNETH R. SPEARS* CHARLES N. HARPER CLAUDIA H, GARY MIRCHANA S. EVERIIART KEVIN POWELL M. TODD BARNETT *ALSO ADMITTED IN TEXAS SWIFT, SPEARS & HARPER, L.L.P. ATTORNEYS AT LAW STREET ADDRESS: 4TM FLOOR FIRST FEDERAL BUILDING 1135 LAKESHORE DRIVE LAKE CHARLES, LA 70601 mkp e-mail: kpowell @law-ssh.com May 16, 2003 VIA HAND DELIVERY Mr. William B. Baggett, Jr. Baggett, McCall, Burgess, Watson 8c Gaughan P.O. Box 7820 Lake Charles, LA 70606-7820 MAILING ADDRESS: POST OFFICE BOX 1810 LAKE CHARLES, LA 70602-1810 TELEPHONE (337) 433-0707 TELEFAX (337) 433-0828 Re: Monsanto VCM Documents Dear Billy: Several weeks ago you and I spoke about documents that I recently discovered at the old site of Monsanto's PVC facility in Springfield, Massachusetts. With this letter are three boxes of documents that I have bates stamped with the labels RSV0022123 to RSV0030026. These documents include those I discovered at Springfield as well as some documents that have been located in the course of the Claude Taylor litigation. I have tagged several documents in boxes 1 and 3. The tag indicates where "gaps" in the bates numbering occurs. These are the locations of documents that I believe are privileged. I'll be revising our privilege log to include these documents. For the most part, they arc documents that were contained in litigation files- attorney notes, drafts of discovery responses, etc. If in reviewing the documents you come upon any additional gaps, please let me know so that I can determine what they are. I caught a couple that was caused by error on the part of the copy vendor. The vendor added a sheet certifying those errors where they were found. As always, we are continuing to search for documents that may be relevant to the VCM cases. As documents are located, I will produce them as expeditiously as possible. I would ask that you please notify your co-counsel in the various VCM matters of this production. If they would like their own copy, I can send a set to a copy vendor for their purchase. If you have questions about any of this, please call me so that we can discuss. With kindest regards, I remain MKP/lsj Enclosure