Document 82azN2j794m5Zjr8dKYoqN9oy

Carter, Ansley, Smith & McLendon Law Okkickh W. COLQUITT CART Eli WJLBHR SMITH MELBUHNE D. McLKM)NA BEN pETTl \' \ ^TT/PtyJo **BAN S I.EY "" , TOMMY T. HOLLAND JAMES B. GURIJSX; . 7j H. SANDERS ^ARTEE,JR. \0~(3 ' ' ' \ ' \ " . \ THOMAS C. BENEDICT . ' ; i iL.^,'7 A. TERRY SORRELLS ^ \ U 'H ROBERT H. STUBBS " ` * . ANTHONY tC. SMITH ROBERT A. BARNABY II ' RONA ID T. GOLD THOMAS E. MAO ILL SUITJE U310, FIRST NATIONAL BANK TOWER Atlanta, Georgia 30303 404. c>ra-922o SHEPARD BRYAN (1071-1070) HENRY M. QUILLIAN, JR. (1927-1972) DECATUR OFI'ICK 203 BBllAU) BED ERA L BUILDING Decatur, Georgia 30030 404 373-6547 March 1, 1979 or COUNSEL BONNEATJ ANSLEY Joe Freeman, Esq. Freeman & Hawkins 618 Fulton Federal Building Atlanta, Georgia 30303 Re: General Electric Co. vs. C&H Transportation Co. (United States District Court) . Dear Joe: We have been missing each other and I thought that I would write to you concerning the nature of my calls. Joe, I understand that you represent the Monsanto Company. In this connection, the defendant's attorneys have advised us that they wish to take the deposition of Monsanto employee, Mr. Kenneth Smith. In an effort to try to hold the expenses of this procedure down (since we understand that Mr. Smith is in St. Louis) we were wondering whether he would have any plans to come to Atlanta in the near future or whether we could otherwise secure his agreement to do so. If we should make our inquiry to Mr. Smith himself, please let me know. However, I understood that you had some contact with him and thought that possibly this would be the proper way to approach the problem. . Very best regards. Yours truly, JBG./dm cc: James H. Fisher, II, Esq. Mr. Robert T. Smales PCB-ARCH-EXT0375788