Document 85N9zZZwq44E9LJE2ZgbKNJQe

NUTTER, McCLENNEN & FISH ONE INTERNATIONAL PLACE BOSTON, MASSACHUSETTS 02110-2699 TELEPHONE: 617 439-2000 FACSIMILE: 617 973-9748 DIRECT DIAL NUMBER: December 20, 1991 18371-1 (617) 439-2460 Keith Minoff, Esq. Robinson Donovan Madden & Barry, 1500 Main Street Suite 1400 Springfield, MA 01115 P.C. Re: Alice L. Warren, Administratrix v. The Dow Chemical Company, Union Carbide, et al Your File No. D-16183 Dear Keith: I am writing to confirm the substance of the settlement discussions we had on Monday, December 16. As indicated orally. The Dow Chemical Company and The BF Goodrich Company jointly offer your client $150,000 to settle this matter. This offer reflects defendants' view that, notwithstanding the very real and clear sympathies underlying this case, plaintiff has a very difficult burden to establish liability given John Warren's prolonged exposure to Monsanto's VCM prior to 1969. We would be happy to continue discussing settlement if you believe it would be productive. Very truly yours SRB/jIf cc: Joseph E. Rendini, Esq 5178i HYANNIS, MASSACHUSETTS COUNSEL: AMSTERDAM LONDON TOKYO