Document 2NBX2xe7VvDg50ZbnnJDKOLRr

Tenneco Oil A Tenneco Company Tenneco Building PO. Box 2511 Houston. Texas 77001 (713) 757-2131 Processing & Marketing December 6, 1983 iltbfciiriED DEC 9 1983 RftUdary T. Shtpird Don Williamson, Esquire The Dow Chemical Company Washington Street Building Midland, Michigan 48640 Robert H. Sand, Esquire Allied Corporation P. O. Box 2245R Morristown, New Jersey 07960 William J. Henrick, Esquire General Tire 8c Rubber Company One General Street Akron, Ohio 44329 Rose Mary Sheppard, Esquire Conoco, Inc. P. O. Box 2197 Houston, Texas 77232 3. Allen Mack, Esquire Occidental Chemical Corporation P. O. Box 699 Pottstown, Pennsylvania 19464 Re: Carol A. Stillo, et al. vs. Rubbermaid Inc, and Tenneco Chemicals, Inc. This letter is to confirm that General Tire, Conoco, Inc. and Allied Corp. along with Tenneco have agreed to retain George Clark from the law firm of Roetzel & Andress to represent each company in this lawsuit. Occidental Petroleum has expressed an interest in joining the group in the event their company (Rubber Corporation of America (Hooker)) is joined in their lawsuit. Dow Chemical is considering joining the group and will advise us of their decision as soon as it is made. Subsequent to our telephone conference call on December 5, 1983, I have been advised that Union Carbide has inquired about joining the group. I advised George Clark to "follow up" this inquiry with Union Carbide and report back to the group. While I am inclined to be in favor of allowing Union Carbide to join the group if they so request, I think all companies in the group should have to approve any such request. We also agreed in our telephone conference call not to enter into a written agreement of joint representation at this time but to reconsider the necessity of such an agreement in the future. In the interim, each member of the group has verbally agreed not to file cross-claims against other group members at this time and to pay all group legal expenses on a pro rata basis. The information previously received from Rubbermaid indicates that the following quantities of PVC have been supplied by each member or proposed member of the A TennecoOil December 6, 1983 Page Two Processing & Marketing group over the applicable years: Dow - 128,000 lbs.; General Tire - 3,869,000 lbs.; Conoco -3,620,000 lbs.; Allied - 9,124,000 lbs.; Union Carbide - 464,000 lbs.; Tenneco 387,000 lbs.; Occidental (Hooker) - 255,000 lbs. Of course, the above stated figures were supplied by Rubbermaid and may not be accurate. For example, Tenneco does not have records indicating the quantities that Rubbermaid has attributed to it. Die following are the phone numbers for each of the respective house counsel: Don Williamson with Dow William 3. Henrick with General Tire 3. Allen Mack with Occidental Pat McGovern with Allied Rose Mary Sheppard with Conoco Richard 3. Lorenz with Tenneco 517-636-9352 216-836-9981 215-327-6400 201-455-5067 713-965-1939 713-757-3722 *V/ George Clark's phone number is 216-376-2700. Very truly yours, R3L:acm cc: George A. Clark, Esquire Roetzei & Andress 20th Floor, One Cascade Plaza Akron, Ohio 44308 Attorney