Document 85x8K5306Oj2xRm6aEZBNEZxk

NUTTER,McCLENNEN 6c FISH ONE INTERNATIONAL PLACE BOSTON, MASSACHUSETTS 02110-2699 617 439-2000 TELEX: 94-0790 TELECOPIER: 617 973-9748 May 10, 1990 18371-1 \J \f((~ Lsffe John R. Downey, Esq. Union Carbide Chemicals and Plastics Company, Inc. Law Department 39 Old Ridgebury Road RECEIVED Danbury, CT 06817-0001 MAY 1 4 1990 Judith Elledge, Esq. Conoco Inc. 600 North Derry Ashford P.O. Box 2197 Houston, Texas 77252-2197 J. R. DOWNEY i Mary Sundt, Esq. The Dow Chemical Company D30 Willard H. Dow Center Midland, Michigan 48674 Re: Alice L. Warren, Administratrix v. The Down Chemical...Company^ Union Carbide, et al Dear John, Judy and Mary: I enclose copies of two letters dated May 4, 1990 from Joseph Rendini, along with the enclosures. I have reviewed briefly the Answer and Jury Claim of Goodrich to the Amended Complaint. The Answer itself is unremarkable. The sheer number of affirmative defenses (32) is, on the other hand, unusual. I would doubt that Goodrich through its counsel seriously intends to pursue all of these defenses in this case. As to the medical records from Monsanto concerning John Warren, I am forwarding them to you without having first reviewed them. In fact, the medical records remain a portion PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" HYANNI& * AMSTERDAM: HOUTHOFF NUTTER McCLENNEN COUNSEL: LONDON TOKYO UCC 082236 NUTTER, McCLENNEN & FISH John R. Downey, Esq. Judith Elledge, Esq. Mary Sundt, Esq. May 10, 1990 Page 2 of the file which I have not yet reviewed and I hope to speak with Mary regarding the review of medical records performed (or to be pereformed) at Dow before undertaking my own review. Best regards. Very truly yours. SRB/jlf enclosures 5178i/9 Sharon R. Burger PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 082237