Document 9327JnppN9Lqk1yqv0RZmEvK3

NUTTER. McCLENNEN & FISH ONE INTERNATIONAL PLACE BOSTON, MASSACHUSETTS 02110-2699 TELEPHONE- 61"419-2000 FACSIMILE. 617973-9748 November 16, 1990 18371-1 i'f uy-Ji DIRECT DIAL NUMBER (617) 439-2382 John R. Downey, Esquire Union Carbide Chemicals and Plastics Company, Inc. 39 Old Ridgebury Road Danbury, Connecticut 06817-6269 Mary Sundt, Esquire The Dow Chemical Company D30 Willard H. Dow Center Midland, Michigan 48674 Judith Elledge, Esquire Conoco Inc. 600 North Derry Ashford Post Office Box No. 2197 Houston, Texas 77252-2197 Re: Alice L. Warren, Administratrix v. The Dow Chemical Company, Union Carbide, et al.; Your File No. D-16183 Dear Counsel: I enclose the following: 1. Interrogatories Propounded by the Plaintiff to be Answered by the Defendant, B.F. Goodrich Company; - 2. Plaintiff's Request for Production of Documents to Defendant, B.F. Goodrich Company; and 3. Documents Produced by Plaintiff in Response to B.F. Goodrich's Document Requests. The documents produced by plaintiff include an extensive diary kept by Mrs. Warren during the decedent's illness. Many of the entries contain extremely graphic depictions of John Warren's deteriorating condition and the various treatments he received. There are also some puzzling entries concerning the decedent's relationship with another woman whom Mrs. Warren refers to as "John's wife." (e.g., entry dated 1/24/88). We will follow up on this area when Mrs. Warren is deposed. PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" HYANNIS, MASSACHUSETTS ( OUNSEL AMSTERDAM LONDON TOKYO UCC 082085 NUTTER, McCLENNEN & FISH John R. Downey, Esquire Judith Elledge, Esquire Mary Sundt, Esquire November 16, 1990 Page Two The entries also briefly discuss the damage to the decedent as a result of his exposure to vinyl chloride. Although Mrs. Warren mentions the possibility of bringing suit against Monsanto, she does not identify any other potential defendants. Plaintiff has also produced bills for psychotherapy treatment sought by Mrs. Warren on July 1, 1990 and August 1, 1990. At this point, we are not aware of any case law or statutory support for an independent claim of emotional distress by Mrs. Warren. Nevertheless, we will certainly look into this further. Very truly yours, Susan L. Parsons SLP:ccn 8444i/5 Enclosures cc: Ms. Yolanda Jackson, Fireman's Fund PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 082086