Document 3JjRRmeX5eORJBp0KN8NZwqvn
UNION CARBIDE CHEMICALS AND PLASTICS COMPANY INC. 39 Old Rldseburv Road
Law Department
Danbury, CT 06817
August 22, 1989
Ms. Dru Toman Union Carbide Corporation Weston Canal Center Post Office Box 450 1 Riverview Drive Somerset, NJ 08873-0450
Re: Joyce M. Brooks v. Union Carbide Corporation (MSDS - 121-2)
Dear Ms. Toman:
Per our discussion on August 22, 1989, 1 enclose pages 2, 3 and 4 of a five-page MSDS.
We are involved in litigation in Indianapolis, Indiana. The plaintiff alleges that he was exposed to certain materials while employed at Essex Wire Company in Indiana. The copy of the attach d MSDS was provided to us during discovery.
I would appreciate it if you would provide us with the most curr nt MSDS oh this particular product, as well as copies of all the MSDSs on this product since 1979.
I would appreciate It if you would provide me with this information by September 5th.
JRD/els Enclosure
PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE
ORDER"
UCC 086187