Document 701592aOv57Z1JpzzGK1aQjGj

N McConnell Valdes Kelley Sifre Griggs &Ruiz-Suria G. P. O. BOX 4225 San Juan, Puerto Rico 00936-4225 TENTH FLOOR NOYAU SANK CENTER 339 NONCE OC LCON AVENUE HATO SET. PUERTO RICO OOSI7 NCREIOA MklEnocz (SOS) 290*3334 Telephone (609) 759-9292 August 11, 1992 CABLE AOOPES3 "MACVAL" TELEX (ITT) 349*0037 (EASVUNK 32343673) OR <R.R. COMM. AUTHJ 333*9222 (ELECTRONIC MAIL ACPR430I33MVK) TELECOPIER (SOS) 799*9223 OR (309) 799*3232 JiU W' VIA FAX? (203) 794-6238 John R. Downeyr Esq. Union Carbide Chemicals & Plastics ,, Co., t^ Ltd. Law Department 39 Old Ridgebury Road Danbury, CT 06817-0001 PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" Re: Luis Aramis Cosme Ruiz, et als. v. Union Carbide Caribe Puerto Rico, Inc.. Kemper National P & C Co., Oscar Castro Barnes. Superior Court of Puerto Rico, Bayambn Part, Civil No. 91-0298 Dear Mr. Downey: There have been some new developments in the referenced case. I have interviewed various persons who assert that plaintiff Luis Cosme has been working driving his taxi until last month when he got suspicious that we were following him. Only one of these persons, Ms. Olga Diaz is willing to testify but only as a last resort. According to the information provided, Mr. Cosme is supposed to get married within the next two months to a girl half his age. Apparently, Mr. Cosme and his girlfriend filed income tax returns together last year 'representing themselves as married. During his deposition, a few months ago, Mr. Cosme denied that he has been working and that he has filed income tax reports. I am in the process of verifying the above information. Tomorrow I will be citing Mr. Cosme's girlfriend for a deposition as well as her parents. I will also subpoena the documents from Rochdale, the taxi company, and several banks. Hopefully we will obtain enough admissible evidence to make Mr. Cosme withdrawal his complaint. UCC 075956