Document 6zpDwQ1N7dkdD4bkaw2gbjrE

F l Trnm* \ Ptttr F. Davy E32S5 Ext. 6255 October 10, 1984 : To: Mr. 0. H. Cunningham ; Mr. E. D. DeLoughy PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 071798 1701 PENNSYLVANIA AVE..N.W, WASHINGTON, D. C. 0006 1 //*, <--> 'V BAKER & BOTTS ONE SHELL PLAZA HOUSTON, TEXAS 77002 TELEPHONE (713) 229-1234 TELECOPIER (713) 329-1730 TELEX 76-2779 ! RECEIVED) OCT 5 1934 f,F, DAVEV 1410 UNITED BANK TOWER 400 WEST FIFTEENTH STREET AUSTIN, TEXAS 78701 D-25,854 Dorothy Bell v. Union Carbide Corporation, et al Mr. Peter ipavey Union Carb de Corporation Old Ridgebip ry Road Danbury, C' 06817 October 2, 1984 PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" Dear Peter :: have, spoken with (george Scott/ whose name was provided to me by yourself or Drl GTermTas being a person who may have some knowledge about suppliers of vinyl chloride monomer to the Texas City Plant. Mr. Scott is currently with Gulf Oil, and his telephone number in Houston is 754-412&. Another former Union Carbide employee named Mike Parkei who was in purchasing at Texas City in 1973-74 works with!Scott, and I had the benefit of hearing from both of them. cott was in production at Texas City from 1957 to 1965 and w&s the product manager in New York for suspension PVC which would have included the Texas City vinyl chloride function f^rom 1974 to 1977. Scott says that all of the VCM which was received at Texas City was of Dow origin. In 1973 and 1974 Robintech and a Japanese concern formed a joint venture called Shintech which was building a plant and receiving VCM even though not yet ready to process it. As a result, the Texas City plant received some VCM from Shintech either directly or through brokers which it tolled. It, however, was of Dow origin. [n 1977 there was an explosion at the Texas City plant and is a result the VCM manufacturing facility was inoperable As a result, Scott was trading Dow origin VCM which Unio Carbide had received and having it tolled at Shintech, diamond and Stauffer into PVC. This, however, would have been again Dow origin VCM and being tolled at other plan zs so the plaintiffs would not have come into contact wi ;h it at all. UCC 071799 AKER & BOTTS 2- - 3) asked Scott about the list of companies you recently provided to me including GAF, Armstrong World, Uvalde Rocri, etc. Scott explained that these companies provided Daw origin VCM to Union Carbide which tolled it into PVC add furnished it back to the customer. hile it is still possible that some of the companies q n the list which fall outside of the dates about which Scotli has awareness sold VCM to Union Carbide, it appears th4 t at least during the period of Scott's presence that all o the VCM received was of Dow origin. Sincerely yours, BAKER & BOTTS FWC:118 :xvBy i-----\ry F. WaTter Conrad PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" ucc 071800