Document 6Rmgyq6E1Gge9z6xaq1YZed4g

Chicago Washington. D.c. LOS ANGELES WOTSR'SOIRECTNUMBER SlDLEY & AUSTIN A- PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 875 Third Avenue New York, New York 10022 Telephone 212:906-2000 Telex 97-1696 Facsimile 212: 906-2021 125th Anniversary 1866-1591 FACSIMILE TRANSMITTAL TOTAL PAGES (INCLUDING COVER SHEET): DATE: February 01, 1995 3 TO: FAX#: FROM* Gregory D. Winfree Union Carbide Corporation 912037946269 Theodore J. Theophilos SlDLEY & AUSTIN NY 212-906-2380 SUBJECT: COMMENTS: IF THIS FAX IS UNCLEAR OR INCOMPLETE, PLEASE CONTACT Theodore J. Theophilos AT 212-906-2380. London Singapore TOKYO PRIVILEGED and SMRNrc!?T NT,AL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 073208 This messagi is memeo only for the use of the ndivbuai or entity to which it is addressed and may contain wformation THAT IS PWVLEGED. CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. IF.THE READER OF THIS MESSAGE IS NOT THE NTEMOEO REORIENT OR THE EMPLOYEE OR AGENT KSPQNSBU FOR DELIVERING THE MESSAGE TO THE INTENDED RECIPIENT YOU ARE HERESY NOTMlEO THAT ANY DISSEMINATION, DISTRIBUTION OR COPYNG OF THE COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THS COMMUNICATION N ERROR PLEASE NOTIFY US IMMEDIATELY IV TELEPHONE AND RETURN THE ORIGINAL MESSAGE TO US AT THE ABOVE ADDRESS VIA THE J.S. POSTAL SERVICE. THANK YOU. CHICAGO LOS AJSTOELBS WASHINGION, D.C. WRITER'S DIRECT NIJMHES (212)906-2380 8cSidley Austin a. PARTNERSHIP DTCLVDIKO PROFESSIONAL CORPORATIONS 875 Thibd Avtentte New Yobs, New Yobk 10022 Telephone 212: 900-2000 Telex 7-1096 Facsimile 21s: 900-2021 125* Aunjtvfe^ajy 1866-1991 February 1, 1995 Co LONDON SINOAJPOHE TOKYO VIA FACSIMILE Gregory D. Winfree, Esq. Union Carbide Corporation Law Department 39 Old Ridgebury Road Danbury, Conn. 06817-0001 PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" Re: Eirven v. UCC&P p ~" 1 o w 1? UU- FEB-6)995 i--------------------------- i G.O. WiNFRFF Dear Greg: I am sending you, under separate cover, the case analysis material for the Eirven matter. As we discussed, Dr. Weir and Dr. Golden will be meeting next week with Karen Myers, Perihan Yalcinkaya, et al, to get them up to speed on the expert issues in the case. Scott Solberg will be there on February 8th and I will join them on February 9th. (Unfortunately I have oral argument in a matter which the court rescheduled for February 8th -- so I will miss the first day.) 1 will be speaking with Karen Myers to confirm the agenda, but they will be meeting with Bob Frantz, Kari Teague, Regina Davis, Bob Arnold and Don Weekes so that we can develop the industrial hygiene defense. Later in the week, Scott will complete the witness interviews ofthe Carbide employees whom Plaintiffs have identified. Starting on Sunday, February 12th, we will begin to take the depositions of the plaintiffs' experts (Legator, Dement and Gardner). In addition, on February 14, we are tentatively scheduled to depose the individuals (ex-Carbide employees) upon whom plaintiffs' experts are relying for data and exposure information. Through Dr. Golden, we have located a few potentially excellent testifying experts. I hope to complete my initial interviews ofthese experts by February 17th so that we can identify them on February 20th. In that regard, I would like to arrange a telephone conference call with Dr. Teta, Dr. Golden and myself to discuss the epidemiology issues in the case. Should I call Dr. UCC 073209 Sidley & Austin Gregory D. Winfree, Esq. February 1,1995 Page 2 New York Teta directly or could you schedule the conference call? I would like to speak with Dr. Teta in advance to discuss the status ofthe litigation. I also need to meet with the Carbide representatives in Danbury whom we may want to call pertaining to the corporate efforts toward safety and high standards regarding industrial hygiene. Could you suggest a time that might be appropriate. Finally, we have not addressed the issue of documents regarding vinyl chloride which may exist at the corporate level. How should we go about getting a handle on those materials. Please give me a call after you have reviewed this letter. TJT/sr cc: Karen Myers (w/encl.) Scott C. Solbert, Esq. (w/encl.) Nathan P. Eimer, Esq. (w/o end.) PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC9JA00.URN (2/1/95 3:33pm) UCC 073210 CHICAGO WASHINGTON, D.C. LOS ANGELES WRITEn'SCMECT NUMBS! SlDLEY & AUSTIN A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 875 Third Avenue New York, New York 10022 Telephone 212: 906-2000 Telex 97-1696 Facsimile 212:906-2021 125th Anniversary IMS-1991 FACSIMILE TRANSMITTAL TOTAL PAGES (INCLUDING COVER SHEET): DATE: February 01, 1995 3 TO: FAX#: FROM* Gregory D. Winfree Union Carbide Corporation 912037946269 Theodore J. Theophilos SlDLEY & AUSTIN NY 212-906-2380 SUBJECT: COMMENTS: IF THIS FAX IS UNCLEAR OR INCOMPLETE, PLEASE CONTACT Theodore J. Theophilos AT 212-906-2380. C<3 london Singapore TOKYO PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 073211 This message is ntended only ran the use of the newdual or entity to which it is addressed and may contain information THAT IS MWLEGEO, CONFIDENTIAL AND EXEMPT PROM DISCLOSURE UNDER APPLICABLE LAW. IP THE READER OF THIS MESSAGE IS NOT THE nTENDED REOPENT OR THE EMPLOYEE OR AGENT RESPONSES FOR DELIVERING THE MESSAGE TO THE NT ENDED RECIPIENT YOU ARE HERESY NOTIFIED THAT ANY DISSEMINATION. DISTRIBUTION OR CCPYWG OF THE COMMUNICATION IS STRICTLY PROHIBTTEO. IF YOU HAVE RECEIVED THIS COMMUNICATION W ERROR PLEASE NOTIFY US IMMEDIATELY BY TELEPHONE AMO RETURN THE ORIGINAL MESSAGE TO US AT THE ABOVE ADORESS VIA THE U.S. POSTAL SERVICE. THANK YOU. ClUOAog Li'iN AM'KI.HH w*smrtlOji, u,u *JtfTKX'$ M. /21250Q6.23M Stdley & Austin tV77\ fHTKr* AviWl.i; Nev 't'OiifL, -Nr:w YfiwK i Tr.i.rtirnKr wj- <k>0*U000 iitu. '00<Voii 1 AluiU&vfsctf*caty idOO-lKSfl February 1,1095 isiNf.iAroXfi: 1HJH VO VIA FACSIMILE Gregory D. Winfrcc, Esq. Union Carbide Corporation Law Department 39 Old Ridgebury Road Danbury, Conn. 06S17-0001 Re; Eirven v UCC&P Dear Greg; 1 am sending you, under separate cover, the cose analysis material for the Eirven matter As we discussed, Dr. Weir and Dr. Golden will be meeting next week with Karen Myers, Perihan Yalcinkaya, et al. to get them up to speed on the expert issues in the c&se. Scott Sotberg will be there on February Xth end 1 will join them on February 9th. (Unfortunately I have oral argument In a matter which the court rescheduled for February 8th -- so I will miss the first day.) 1 will be speaking with Karen Myp.rs to confirm the agenda, but they will be meeting with Bob Frantz. Kari Teague. Regina Davis, Bnh Arnold and Don Week.es so that we can develop the industrial hygiene defense. Later in the week, Scott will complete the witness interviews of the Cat bide employees whom Plaintiffs have identified. Sinning on Sunday. February 12th. we will begin to take the depositions of the plaintiffs* experts (Legator, Dement and Gardner). In addition, on February 14, we are tentatively scheduled to depose die individuals (ex-Carbidc employees) upon whom plaintiff*' expens are relying for data and exposure information. Through Dr. Golden, wc have located a few potentially excellent testifying experts. I hope to complete my initial interviews of these experts by February 17ili so that we can identify them on February 20th. In that regard, I would like to arrange a telephone conference call with T)r. Tcta, Dr. Golden and myself to discuss the epidemiology issues in the case, Should I call Dr. privileged and "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 073212 hXTJr. KY A TTKTl.V Gregory D. Wmfree, Esq. Kubruvy I 199S Page 2 M kw Yokk Tera directly or could you schedule the mnfrrpnr* call? I would like to speak with Dr. Tela in advance lu discuss the status of the litigation. T also need to meet with the Carbide representatives in Danbury whom we may want to call pertaining to the corporate efforts toward safety and lugh standards regarding industrial hygiene. Could you suggest a time that might be appropriate. Finally, we have not addressed the issue ofdocuments regarding vinyl chloride which may exist at die corporate level How should we go about getting a handle on those materials. Please give me a call after you have i eviewed this letter. TJT/sr cc: Karen Myers (w/end.) Sum C. Solbert, Esq. (w/end.) Nathan P. Eimer. Esq. (w/o end.) UCC95AW.UKN (2/I/M 3i3pm) PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 073213