Document 6wO8MQY91ZjOmK4RQG9goveo6

ROI"T L. MOILINQJHIAO ----------DIRECT DIAL NUM6ER (*OI) 631*4617 /t ' /' Pitney, Hardin, Kipp & Szuch 163 MADISON AVENUE P. O. BOX 1945 MORRISTOWN, NEW JERSEY 07960-1945 MORRISTOWN (201) 267*3333 NEW YORK (2l2) 928*0331 ----------TELEX 642014 TELECOPIER (201) 267*3727 f.h -* NEWARK OFFICE 33 WASHINGTON STREET NEWARK, NEW JERSEY 07102 (201) 023*1660 August 28, 1989 VIA FEDERAL EXPRESS John Downey, Esq. Onion Carbide Corporation Law Department E3-285 39 Old Ridgebury Road Danbury, CT 06817-0001 HECEiVED m 2 9 tm j. r. cc.v;;3 Re: Peterson v. Union Carbide Corporation Dear John: Enclosed please find draft answers to the plaintiff's Supplemental Interrogatories in this matter. Please note that these answers were prepared following the receipt of proposed answers by Nick Wheeler, a conference with Nick in my office on August 16 and 17, and close scrutiny of the answers to five sets of Interrogatories in the Maliko case from 10 plus years ago. You will note that several of the answers contain comments in brackets. Those comments are intended to remind either Nick or me as to certain follow-up steps that should be taken. For Nick, the primary follow-up is to check the accuracy of Some of the information about OTD/ATC with Mr. Bowles or other individuals within Union Carbide. By another letter of this date, a copy of which is enclosed, I am asking Nick to kindly review the answers as soon as possible and complete whatever contacts he needs to make in order to verify the answers. If you can do the same, it would be greatly appreciated. PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 088560 Pitney, Hardin, Kipp & Szuch John Downey, Esq. August 28, 1989 Page 2 Betsy Weiss and I are looking forward to meeting you at our Morristown office on August 31 between 10 and 10:30 a.m. If you and Nick have completed your reviews by then, perhaps we can even finalize the answers at that time. Sincerely, *2 ROBERT L. HOLLINGSHEAD ) RLH:lh Enclosure PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 088561