Document 8R38JGGLb6m4VEenyQmg5DakZ

JUN 20 '94 10:33 FROM THE GEON CO - EX ROU TO B-2153417797 PAGE.001 r? 410ft f)?lr Tre Boulevard Cleveland, Ohi 44131 116-447-6001 Fax: 216-447-S146 June 17, 1994 To Legal Committee of the Vinyl Institute RE: Legal research on Greenpeace related issues Gregory L Rutman vice President General Counsel and Seuclary c As some of you may know, I assumed leadership of die Legal Committee of the Vinyl Institute. On Friday June 17, 1994 the Executive Committee of the VI authorized engagement of outside counsel to review legal strategy and issues raised by the recent spate of Greenpeace ann-PVC literature. I need your help. There follows a list of requirements identified for any outside counsel we retain. Please feel free to add to this list and most importantly give me your suggestions of any individuals you may know that are potentials. When the list gets narrowed, I will consult with you on final selection. We will, of course, consider Keller & Heckman in the process, particularly since they have just associated with a liligation firm. OUTSIDE COUNSEL REQUIREMENTS National reputation as knowledgeable in State A Federal free speech issues, product disparagement, tortious interference with contractual rights and fiaud issues. Must have technical/chemical experience. A firm that has no qualms about taking on Gxccupcacc if it comes to that A firm that is known to have reputable, conservative hilling practices A firm that has bandied similar cases for other clients An experienced litigator with mature judgment who eats naik for breakfast. Please call me ASAP with your ideas and comments. Regards, cc: Bob"Sumeu VI Peter de la Cruz-Keller & Heckman Post-It' brand lax transmittal memo 7571 * * p*g * / M` Cp ** TOTAL PAGE.001 **