Document 4JEReDM42rwJQDowY1oadqGap

UNION CARBIDE CORPORATION old riogebury road, danbury ct osai7 LAW DEPARTMENT EXPRESS MAIL May 20, 1985 Cheryl Hoffman, Esquire Gibson, Dunn & Crutcher 333 S, Grand Avenue Los Angeles, California 90071 Re: Vera Morris v. Lockheed Corporation, et al.t including Union Carbide Corporation as Doe 12 California Superior Court, Los Angeles County Case No. C-409257 Dear Cheryl: Pursuant to our telephone conversation on today's date, you have agreed to represent Union Carbide Corporation in the above-captioned matter. I enclose a copy of the summons and complaint, as well as a memorandum dated May 10, 1985 concerning our sales to Lockheed and a memorandum dated May 13, 1985 concerning trichlorethane. The Corpora tion was served on April 30, 1985 and we have until May 30, 1985 to answer. Thank you for representing us in this matter. Very truly yours, ykictfo. p MJF*.mh Enclosure Martha J. Friar cc: L. A. Crisorio - P2-608 (without enclosure) E. D. DeLoughy - B4-155 (without enclosure) - Has Kemper been notified? South Charleston (without enclosure) C. C. Ivie, Esq. - Gibson, Dunn & Crutcher (with enclosure) G. Justice, Esq. - Gibson, Dunn & Crutcher (with enclosure) PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" ucc 044454 UNION CARBIDE CORPORATION Ethylene Oxide/Glycol Division RcCfclVcd MAY 17 1985 Old Ridgebury Road R, N, WHEELER Danbury, CT 06817 Hay 13, 1985 TO: H. Friar CC: R. N. Wheeler In regard to the litigation in which an employee of Lockheed Aircraft in Burbank, California alleges Injury from exposure to trichlorethane supplied by Union Carbide, I wish to make the following comments. Union Carbide did make and sell ethylene dichloride up until 1972 when sale of this product was discontinued. To my knowledge, Union Carbide has never made or sold trichlorethane. Very truly yours. JHC:pmh 0142h P.71 John H. Cole PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" uanrornia nuui u unc , j. > , ^ 1 .. w-..___, _. . . was exposed to polyvinyl chloride materials, tri-chlorothide ethane, as well as other chemicals and materials, which were used in the manu facture of airplanes and airplane parts. On May 7, 1981 she discovered she had scleraderma which has prevented her from working from February, 1979 to the present. She is claiming more than $20,000,000 compensatory damages and $75,000,000 punitive damages. By copy of this letter to Nick Wheeler, would he please check the Corporation's sales records to see if we were a supplier to Lockheed Corporation during the 1978-1979 time period. The chemical "tri-chlorothide ethane" as specified in the complaint is possibly a misspelling of trichloroethane. Nick Wheeler has initially indicated that Union Carbide has never sold trichloroethane, but this will have to be verified. By copy of this letter to Ed DeLoughy, would he please notify the appropriate insurers of this pending lawsuit. Very truly yours, .. MJF:mh Enclosure cc: A. M. J. F. C. E. Z/LtC'Z* / '."ic**. i Martha J. Friar Rubinson - E3-259 (without enclosure) Skislock - D2-241 (without enclosure) Van Dyk - E2-289 (with data sheet) - Please add this case to our group of polyvinyl chloride cases. PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" occ 044451 /?7? PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" ucc 044482