Document 7M7GRg7nzZmpxjq0w7wmkEmRV

INTERNAL CORRESPONDENCE P. O. BOX 471, TKXAS ClfV, tXA* 771 TO: Ms. Betty Lyon White Law Dept - E228I Danbury Office CC: Hr. 0. B. Whittington Dr. D. H. Glenn Ms. Noreen Pritchett DATE: January 31, 198-1 RE: Dewey Bell, Dec (T&P Retiree 10 vs. Dow Chemica Subpoena For Di^e Dear Hs. White: Per my recent conversation with John Day, I enclose a copy of the subpoeri; direct questions responded to today in the subject suit for your records, records are maintained locally on vinyl chloride purchases, the current in the General Purchasing Department have been named for obtaining ' fijr information. Mr. Bell has been terminally ill due to Glioblastoma since his total and disability retirement 10/1/82, and died January 6, 1984. He filed a claJ Worker's Compensation in April, 1982, and a copy of the negative Employer^ was sent to John Whittlesey by Dr. D. H. Glenn on April 21, 1982. According to Noreen Pritchett, our Kemper rep*sentative, several pre-heai on this case have been scheduled but cancelled by his attorney, David A. :>1< In the meantime, he has been loading Reapers' f ie with medical data. To 4at no compensation has been paid, of course. The above information is furnished for your background information only ai time as I complete this subpoena request. Any further inquires should be lie to Mr. D. B. Whittington as I am now in another assignment and have no re* \po ties in benefits administration and worker's compensation litigation matti Sincerely, DCH:ar Enclosures D. C. Heyen ER Staff Administrator PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" ucc 059013 Dewey Bell, ec ux : Plaintiff v Dow Chemical Co : Defendent C - 83 - 4fi Civil Actlcn Number Direct questions to be propounded to the witness, Custodian of Records for Union Carbide Corporation. 1. Q. Has Dewey Bell ever been an employee of Union Carbide Corporation? A. Yes 2. Q. For each position or Job description which Dewey Bell has ever held with Union Carbide, please state the following: a. The position or job title: b. The dates that Dewey Bell held the position: c. The duties which Dewey Bell performed: d. The names and current addresses of Dewey Bell's supervisor(s) In the position or job function: e. Whether Dewey Bell worked with vinyl chloride or any prodeucts containing vinyl chloride: f. If he did work with such products, what activity or work he performed with the product: .2. A. Job #1 a. Laborer b. 5/27/55 to 11/12/63 c. General labor work - no job description exists. d. Unknown specifically for this period. See Exhibit I for names of all supervisors of record. e. No record of any exposure. f. Ditto Me". Job #2 a. Tool Room Attendent b. 11/12/63 to 12/1/71 c. No job description exists - General storekeeper activity in tool supply - check tools in and out. d. See Exhibit I - unknown specifically this period. e. No record of any exposure. f. See "e". ucc 059014 PRIVILEGED AND " CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" Dewey Bell, et ux ve. Dow Chemical Company C-83-48 Page 2 2. A. Job #3 a. Maintenance Supervisor b. 12/1/71 to 9/29/81 (Last Day Worked) c. Supervised various types of maintenance Jobs being performed in areas to which he was assigned. . ,Area 44 (8 years) - #3 Olefins, Docks, Linear Alcoh 0 8 Normal paraffins Area 43 (3 Years) Ditto above + In-Plant Distribu t Lon d. See Exhibit I e. No record of exposure f. See "e" 3. Q. Does Union Carbide have any records of purchase of vinyl chloride? If so, who is the custodian of such records and what is his tit lc? A. Yes. E. F. Krainer, General purchasing Department Union Carbide Corporation Old Ridgebury Road Danbury, Conn. 06817 4. Q. If Union Carbide has any record of purchase of vinyl chi oride or products containing vinyl chloride, please state the following fo r each product: a. From whom it was purchased: b. The dates of purchase: c. The name and quantity of the product purchased: d. Any invoice numbers pertaining to the purchase of such products: e. Attach a copy of such invoices to this deposition: A. Vinyl chloride has been purchased from the following ven d'>rs; however, contract copies nor invoices are retained at this locatl o&. All such records are in the custody of Union Carbide Corporation1 a General Purchasing Department. See Question 3 for contact: Dow Chemical Company PPG Industries Stauffer Chemical Company Diamond Shamrock Corporation privileged and "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 059015 Dewey Bell, et ux vs. Dow Chemical Company -|b3-48 Ifaje 4 Witness (Custodial of Records Before me, the undersigned authority, on this day persor ally appeared, Custodian of Records fc r Union Carbide Corporation, known to me to be the person whose name is subscribed to the foregoing instrument in the capacity therein stated, in|d acknowledged to me that the answers to the foregoing questions are true as stated. 1 further certify that the records attached hereto are exact duplicates of the original records. Given under my hand and seal of office this . 1984. da) of Notary Public ii and for the State of Texas David A. Slaughl t r Attorney for Pli<ntiff Dewey Bell, et TXtf 18488000 PRIVIL HGED AND "CONFIDE ^TIAL MATERIAL SUBJECT]- O PROTECTIVE RDER" ucc 059017 EXHIBIT I ATTACHMENT - SUPERVISORS J. P. Alexander " Retired - Route 2, Box 235, Livingston, Te{x^s 77351 R. F. Bobbitt - Retired - Date Of Death; 7-19-79 P. B. Bottlng - Active - 109 Bayou Drive, Hitchcock, Texas l7t563 T. O. Blum - Active - 1525 22nd Avenue North, Texas City, Tex^s 77590 J. R. Dement - Active - 3518 Sweeney, Dickinson, Texas 7753) T. F. Drummond - Retired - 808 16th Avenue North, Texas City Texas 77590 J. T. Floyd - Active - 2709 Belmost, Dickinson, Texas 77539 J. A. Frederlcksen - Address Unknown - Left Carbide R. E. Kirkland - Retired - 3707 Rau, Dickinson, Texas 77539 E. C. Pauls - Retired - 214 West Bayou Drive, Dickinson, Texm 77539 P. R. Schmeppe - Active - P. 0. Box 8361, South Charleston, (Engr - Tech Center) st Virginia 25303 E. E. White - Retired - 1109 Estates Drive, La Marque, Texas 77568 rv*ePWv'- confide GfDAND subject protJERial ROTec^ ucc 0590ta