Document 6REJ8VeGzXVGVojaJpmgzMv9m
NUTTER, McCLENNEN & FISH
ONE INTERNATIONAL PLACE BOSTON, MASSACHUSETTS 02110-2699 TELEPHONE: 617 439-2000 FACSIMILE: 617 973-9748
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DIRECT DIAL NUMBER:
January 23, 1991 18371-1
Keeper of the Medical Records for Paul M. Quinlan, Ph.D. Behavioral Science Associates 380 Union Street West Springfield, MA 01089
Re: Alice L. Warren v. The Dow Chemical Company,
S3-30 ZD IE___________________
Dear Sir or Madam:
Please be advised that this office represents the
defendants Union Carbide Chemicals and Plastics Company, Dow
Chemical Company and Conoco, Inc. in the above-referenced
case. As part of our pretrial discovery in this case we need
to examine all the medical records of Alice Louise Warren of 40
Midway Street, Indian Orchard, Massachusetts 01151. To this
end, you are being served with a Notice of Taking Depositi
CPand Deposition Subpoena requesting you to bring these records
to the office of/Nutter, McClennen & Fish, One International
Place, Boston,
02110-2699 on Monday, February 25, 1991 at
a.m. {fa (If
Since our main objective is to obtain the records themselves, we would not require you to appear for deposition if you would agree to forward the requested records to us as soon as possible. If you decide to do so after being served with the subpoena, please indicate this by checking the box provided at the bottom of this letter and returning it to me by return mail. A self addressed stamped envelope is enclosed for your convenience.
Very truly yours,
J1
RECDVED
SRB/bjm Enclosure
Sharon R. Burger
FEB 0 hWi
i a Domt
/_/ I hereby agree to produce the requested record| and will forward them to you immediately.
bcc: John R. Downey,. Esq.
Judith Elledge, Esq. Mary Sundt, Esq. Ms Yolanda Jackson
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