Document 5k24jGrZ7nOdENjQKJ3eq4K2N

FROM Ht-t-' 503 528 7151 '= - U i * =>". m tfiL U -U M 9COTT BALDWIN BmCAORTHTV BLA. L(DDW'LI'NG. >JCRLAM JA C K | R 9 W K BALOW iN law o ^ rtc c s ft BALDW IN & BA LD W IN 40 0 W*5T HOUSTON S T R E It M AJRSttiAL,Li T B X A 5 TELEPHONE B3B-AISI April 29, 1993 A 9 . BMAWKR ISAB m A R I H ALL T i n * * * M T I Ms. Carol Van Btrum (303/528-7105) 7493 East Five Rivers Road Tidewater, Oregon 97390 Dear Carol: Confirming our telephone conversation of this morning/ I would appreciate it if you could send me the following information: 1 All API documents upon which International Paper is shown as being copied. I believe all of these are included in the memo which you forwarded to me last August. 2 . Any API d o c u m e n t s which you have in your possession regarding the dioxin/pollution of the River issues. Again, it would be my hope during depositions to show that whether IP is copied on such documents or not, that they are certainly applicable. 3. Any depositions of API officers, directors, stc. which you have. incidentally, I would be interested in the procedure that you had to follow to get the API depositions, Did they voluntarily appear or did you have to notice them, etc. If you have a copy of any notice that you prepared including any subpoena ducts tecum 1 would appreciate a copy of that as wall, As always, please Bend me a bill for any work that is performed. I !ll be more than happy to report back to you concerning the results of my depositions of the API people if it is of coroo in%W6Bt tfl. y o u . HLGjr/cg