Document BReRnxo4adgZdz22KgnVwxgBE

CHICAGO LOS AJS~GELTW WASHINGTON, E.C. WHITES*S DIRECT NUMBER (212) 906-2380 Sid ley 8c Austin A. PARTNERSHIP XMCLUDWa PROFESSIONAL CORPORATIONS 875 T hi hd Avenue New Yobs, New Yohe 10022 Telephone 212: 908-2000 Telex. 7-1098 Facsimile 212: 00-2021 125th- Ax{iuivfei3>aiy' 1866-1991 November 9, 1994 CP LONDON SINGAPORE TOKYO Gregory D. Winfree, Esq. Union Carbide Law Dept. - E3-282 39 Old Ridgebury Road Danbury, CT 06817-0001 Re: Eirven ^y. UCC&P Stevenson v. UCC&P Dear Greg: Enclosed is a copy of the Joint Motion to Extend Time to Identify Experts in the Eirven matter, which we received from Reggie Wood, along with his letter to Catherine Baen regarding outstanding discovery matters in the Eirven and Stevenson matters. Sincerely, `/jLC TJT/sr Enclosure Theodore J. Theophilos PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" lips innn w n i *~i t NOV I 4 1934 I j i, ii i G.D. WINFREE UCC 073329 UNION CARBIDE CORPORATION SOLVENTS & COATINGS MATERIALS DIVISION Ill) 'i'rody Cc> November 8,1994 VIA FAX Theodore J. Theophilos, Esq Sidley & Austin 875 Third Avenue New York, NY 10022 Re:;*rEtfyei\y. UCC&P / PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" Dear Ted: This note is to let you know the first shipment of documents is leaving the plant this afternoon. The following explains the boxes leaving 11/8/94: Boxl: Original SVR documents Box 2: Original SVR documents (smaller box) Box 3: Original SVR documents a. Please note file "OSHA Citation, July 1974" b. Please note file "OSHA Regulation Legal Considerations" (This file is located immediately following the "Gas Mask" file) Box 4: Industrial Hygiene Monitoring Data 1974 -1989 (smaller box) (Do not need to copy this box) As we discussed, Boxes 1-3 will be copied, and the original documents will be returned to the plant. I have not had time to look through these documents but there appears to be a lot of IH monitoring data in them as well as some training records. Tomorrow, I will ship some more boxes with a general explanation of each. When you get a chance, can you fax or mail the action items I could not get printed for you last Friday afternoon? Thanks. Sincerely, Karen M. Myers /km 4^Boxes via Airborne Express for 11/9/94 arrival v/occ: Greg Winfree, Esq. P.O. BOX 471. TEXAS CITY, TEXAS 77592-0471 UCC 073330