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PLAINTIFF'S EXHIBIT CAUSE NO- 2000~05~1962~C ROBERT HENRY VILLARREAL, OFIndividuallv and as Personal Representative of the Heirs and Estate of JOHN HENRY VILLARREAL Plaintiffs, VS. TEXAS UNION CARBIDE CORPORATION Defendants. IN THE DISTRICT COURT CAMERON COUNTY, 197th JUDICIAL DISTRI PRIVILEGED UNION CARBIDE DOCUMENTS 1, April 16, 1974-Letter-Medical Directors Meeting TO: John Whittlesey, Attorney FROM: E. Q, Hull, M.D./SHARE MEDICAL RE: Seeking legal opinions in regards to medical treatment and OSHA compliance. Privilege: Work Product pursuant to Rule 192.5 (a)(1), (2):(b) (1), (2) ofthe Texas Rules of Civil Procedure. 2. May 8, 1974-Letter-LegaI Opinion on Industrial Hygiene and Medical Care TO: E.Q. Hull, M.D./SHARE MEDICAL; and W.W. McManus at the Brownsville facility June 10, 1974, FROM: John Whittlesey. Attorney RE: Legal opinion regarding existing known defects or hazards. Privilege: Work Product pursuant to Rule 192.5 (a)(1), (2);(b) (1), (2) ofthe Texas Rules of Civil Procedure. April 20. 1976-Speech given by John Whittlesey, Attorney TO: Joint Industrial Hygiene/Medical Dept. Annual Meeting in Gatlinburg, Tennessee RE: Legal opinions regarding the relationship between OSHA standards and independent contractors. Privilege: Work Product pursuant to Rule 192,5 (a)(1), (2):(b) (1), (2) ofthe Texas Rules of Civil Procedure. 4, November 30,1977-Letter regarding Industrial Hygiene TO: Various Employees FROM: A.E. Montagna/SHARE-Environmental Protection & Occupational Health Page 1 cn RE: Legal Opinion from John Whittlesey regarding contract personnel. Privilege: Work Product pursuant to Rule 192.5 (a)(1), (2);(b) (1), (2) ofthe Texas Rules of Civil Procedure. 5. March 20,1978-Letter Regarding NESHAPS 40 CFR 61.20 TO: Environmental Coordinators FROM: Law Department RE: Legal analysis of asbestos regulations under the Clean Air Act. Privilege: Work Product pursuant to Rule 192.5 (a)(1), (2):(b) (1), (2) ofthe Texas Rules of Civil Procedure. 6. July 20, 1978-Letter on Monitoring Contract Personnel TO: W.W. McManus and R.C. Glock CC: K. Gran Townsend and Ben Brown FROM: L.T. Windel (Disseminating recommendations by Jim Murray and Joe Triplett from UCC legal department). RE: Legal opinion from UCC Legal Department regarding contractor employee and industrial hygiene. Privilege: Work Product pursuant to Rule 192,5 (a)(1), (2);(b) (1), (2) ofthe Texas Rules of Civil Procedure. 7. September 19,1978-Letter on Contractor Employee's Exposure TO: J.C. Schonberg FROM: T.A. Moore UCC legal department RE: Legal opinions regarding contractor responsibilities in monitoring employees, safety equipment, hazard data and compliance with OSHA. Privilege: Work Product pursuant to Rule 192.5 (a)(1), (2):(b)(l), (2) of the Texas Rules of Civil Procedure. 8. November 1, 1978-Letter with attached T.A. Moore, UCC legal department opinions regarding contractor responsibility TO: L.T. Windel, R. Glock, and A.L Barefoot FROM: K. Gran Townsend RE: Legal opinions re:Contractor Employees'. Privilege: Work Product pursuant to Rule 192.5 (a)(l), (2);(b) (1), (2) oftire Texas Rules of Civil Procedure. 9. March 14, 1979-Letter regarding Brown & Root Maintenance Contracts for the Seadrift, Brownsville, and Deer Park Plants. Contains written note regarding legal department's legal opinion re: contract language dealing with occupational health responsibilities. TO: Dave Jones FROM: J. E. Murray RE: Brown & Root Maintenance Contracts and legal opinions. Page 2 Privilege: Work Product pursuant to Rule 192.5 (a)(1), (2);(b) (1), (2) ofthe Texas Rules of Civil Procedure. ] 0. December 1, 1990-Letter UCC law department regarding re: negative pressure enclosures under the OSHA asbestos standard. TO: Distribution list not attached FROM: M..N. Duvall and R. E. Plevan RE: Legal analysis of OSHA's negative pressure enclosures under the asbestos standard. Attachments: OSHA memorandum re: enforcement policy regarding negative pressure enclosures and related issues. Privilege: Work Product pursuant to Rule 192.5 (a)(1), (2);(b) (1), (2) ofthe Texas Rules of Civil Procedure. 11. June 12, 1991-Field Footage Log-Log of videotape of the UCC Brownsville Plant created by Legal Productions containing attorney's mental impressions. Privilege: Work Product pursuant to Rule 192.5 (a)(1), (2);(b) (1), (2) ofthe Texas Rules of Civil Procedure. 12. January 3, 2001 - Note regarding exhibits containing mental impressions, conclusions, and opinions in UCC Brownsville litigation. TO: John Bissell, Strong, Pipkin, Nelson, Bissell & Ledyard FROM: Virginia Ruszcyk, Kelly Drye Attachments: Exhibit A - Center for Claims Resolution list of all pending claims in Brownsville. Exhibit B - UCC IH survey done by R. E. Peele re: bandsaw in Brownsville plant insulation shop. Privilege: Work Product pursuant to Rule 192,5 (a)(1), (2);(b) (1), (2) ofthe Texas Rules of Civil Procedure. 197315 Page 3 attorneys at law 2600 Two Houston Center . 909 Fannin . Houston, Texas 77010-1009 Telephone (713) 767-1555 . Facsimile (713)767-1799 July 10,2001 Stephanie Finch Baron & Budd 3102 Oak Lawn Avenue Ste. 1100 Dallas, Texas 75219-4281 RE: Cause No. 2000-05-1962-C; Robert Hemy Villareal, et al vs. In the 197th District Court, Cameron County, Texas Plaintiff: Robert Henry Villareal for John Henry Villareal (deceased) Defendant: Union Carbide Corporation Dear- Ms. Finch: In response to your June 26, 2001, letter requesting a privilege log as to all material and information being withheld by Union Carbide Corporation on grounds of privilege, please see the attached privilege log. Attachment LW/sb Lori Wiese