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