Document KR9LyMoBjooRBbQ758n88Xe16

-MLiLl -ir'.PI Jrsno 1rf7nu/96iitu0i2' 20PM nDnOoWuunLE. GoALc.w7TcH FL JTJL l7 '9S 1013aer\ OOU LEGFL FTH FL FAX HO. 14072430038 P.2/3 P.2/3 ` IN THE UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA ANDERSON DIVISION Dale and Emily Owen Plaintiffs, v. Thu Daw Chemical Company, Defendant. CA. No: 8:96*360*3 AFFIDAVIT OF WILLIAM A. grqening; jr. AFFDAVIT of WILLIAM a. GROENING, JR. I J \ j L WiUisuu A- Greening. Jr., being sworn, stare the following: j (I j -j 1. My name is William A. Greening, Jr. I am older tban IS years of age and I a^n, in all ways, qualified to testify. 1 am testifying from my own personal knowledge.; Z I was employed by The Dow Chemical Company ("Dow") and worked in Dow's Legal Department as an attorney continuously from January 4,1937 until I retired on November 30, 1977.1 served as Dow's General Counsel from January 1968 Imtil May 1977. ; 3. In 1958, in my capacity as Dow's Assistant General Counsel, I participated in drafting the agreement between Dow and BASF Oversee N.Y. C'BASF1 to form The t Daw-Badiscbe Chemical Company, Inc. ("Dow*Badische,T). From 1958 until I retired i in 1977,1 received and was responsible for maintaining for Dow copies ofDow- Badisehe's Board of Director and Shareholder meeting minute*. To the best of my i JL"i I-"20 "rtci/ Ti uT itnuouu'u uuvju JVL 17 '36 ia:34Pf1 DCU LEGflL 7TH rL rccoiieccian, throughout this period Dow*Badischs hold regular quarterly Board of Director meetings and regular annual Shareholder meetings, j further affiant sayetfl hoc Dated this 17tb day of July 1996. STATE OF FLORIDA COUNTY OF PALM BEACH ) (SS. ) Subscribed and Sworn Before Me this 17* day ofJuly 1996