Document 2JzYOZerv5MX25XZpXDN1xOkb

Robert e. Purgatorio Hays, McConn, Rice & Pickering A PROFESSIONAL CORPORATION ATTOBNBYS AT LAW 400 TWO ALLEN CENTER 1200 SMITH STREET 2(02 f'jjpj 28 HOUSTON, TEXAS 77002 TELEPHONE (713) 654-1111 TELECOPIER (713) 650-0027 AH 9: 13 Direct Line: (713) 752-8351 E-Mail: RPurgatorio@HaysMcConn.Com August 27,2002 Mr. Scott Frost Mr. Stephen Johnston Baron & Budd, P.C. 3102 Oak Lawn Avenue, Suite 1100 Dallas TX 75219-4281 Re: Cause No. CC-01-05948-C; Marie Ruth Auzenne, individually and as personal representative ofthe heirs and estate ofJoseph TalbertAuzenne, deceased vs. U.S. Gypsum Company, etal.; In the County Court at Law No. 3, Dallas County, Texas Dear Gentlemen: Pursuant to the agreement we reached in connection with the challenges made to the discovery objections filed on behalf of Ethyl Corporation in the above-referenced matter, and as a formal supplement to those discovery responses previously filed herein, as well as to any and all other discovery responses made by the company in this case, I am enclosing documents bearing Bates Stamp numbers ETH00002472 through ETH00003676. Additionally, this will also serve to confirm that the documents previously provided by Steve Rice ofthis firm on behalf of Defendant Ethyl Corporation are to be considered part of this formal supplementation of Ethyl documents in response to the Plaintiff's discovery requests. Still further, we are in receipt of CD-R.om disks produced by.your firm cataloging Ethyl Corporation documents obtained in other litigation. Although it is very likely there is a great deal of duplication in the documents previously provided to your office as well as the documents attached hereto, Defendant Ethyl Corporation reserves the right to rely on any of the documents imaged on the CD's by your office to the extent they are Ethyl documents and actually obtained from the files of Ethyl Corporation. REP/574023 Mr. Stephen Johnston Mr. Scott Frost August 27,2002 Page 2 Should you have any questions, please do not hesitate to call. Sincerely yours, PICKERING REP/lg Enclosures REP/574023