Document Ezx9kjdGbzEbnZXEQZ0JjLpR

Pitney, Hardin, Kipp & Szuch [MAIL TO! P.O. BOX 19-45 MORRISTOWN, NEW JERSEY 07962-1945 7 ts C ROBERT L. HOLLINGSHEAD DIRECT DIAL NUMBER (SOI) 966-8017 (DELIVERY TO) 200 CAMPUS DRIVE FLORHAM PARK, NEW JERSEY 07932 FLORHAM PARK (201) 966-6300 NEW YORK (212) 926-0331 Newark ornce 33 WASHINGTON STREET NEWARK, NEW JERSEY 07102 (201) 623-1980 PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" TELEX 642014 FACSIMILE (201) 966-1550 September 11, 1991 John R. Downey, Esq. Union Carbide Chemicals and Plastics Company, Inc. Law Department E3-285 39 Old Ridgebury Road Danbury, CT 06817-0001 Re: Colbv v. Union Carbide Dear John: Please be advised that we have been served with (1) Interrogatories, (2) Supplemental Interrogatories, and (3) Requests for Admissions from the plaintiffs' attorneys in this matter. The answers to the Interrogatories and Supplemental Interrogatories will be due on November 5, 1991. The answers to the Requests for Admissions will be due on October 5, but I have obtained an extension until November 5 for those answers, too. All of these discovery requests appear identical to those in the Peterson and Bernadino cases. Therefore, I will prepare identical answers wherever possible. To the extent that I require additional information, I will let you know. When the answers are prepared, I will send them to you for your review. I am not sending you copies of these discovery items at this time because of their volume and because I do not believe that you need to see them until we have prepared answers. I will assume that you agree unless I hear from you to the contrary. UCC 076164 Pitney, Hardin, Kipp 6. Szuch John Downey, Esq. September 11, 1991 Page 2 Please advise me if Nick Wheeler will serve as my technical advisor in this case, as he has in other PVC cases. If so, either you or I should put Nick on notice as to the existence of the suit and his role. Best regards. Sincerely, RLH:pc cc: R.C. Wise ROBERT L. HOLLINGSHEAD PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 076165