Document LpG0QX6dpNxQrwXOwrNwvwgNq

*-&uz-irr4-. ^ <3+d. -yi^ SU ^%be*r*- &&*p*>ttii2?. . te&bfd&d&?- ##// July 31* 1985 f/#J MT.fSM i2rddi '.^wwW 2fac* 22&y*te* / frf`<f'/`-<f//S S f2/#J ##/ <?/<?& (216) 687-8741 Martha J. Fr iar, Esq. Law Departme nt Union Carbid e Corporation Old Ridgebur y Road Danbury, Cor necticut 06817 AUG 51985 U.10OAR Re: Neff, Perkins, Sheppard, and Whltmer Dear Martha: I acn enclosing a copy of Celanese's Answers to Plain tiffs* Inter rogatories . Yooi Wi^^iiafe^t^at^gfttageife^denfetfAftar Stauffer Che nlcal Company, B.F* Qoodrleh^'w^.^Ccil^drilClSEkPjon^^aa the suppliers of PVC* s^or VCT to its -Hilliard *\OhiQLfacility between Jan 1 ry 1, 1968 and January 1,^1981 JInterrogatory No 14). Cel anese claims that It had meetings, which all manu- facturing pe rsonnel attended, warning them of the dangers of VC and PVC. A reading of the interrogatories as a whole makes It clear that t hese meetings took place some time after OSHA regu- lations bee akne effective. If you have any questions, please call me. Very truly yours. rIM A Mitchel (B, Axler MBA:dms Enclosure cc: Mr. W. C Brown (w/encl) PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 071327 ^o/eem/ai-, $*& /ifuz.,mu.', <s'le*a- Stettt @k*>et**x:. i-Q^ynwg <dze&- July 8, 1985 RECEIVED fxz// ' Ms.<fS00 ' MS-(ft?/ f/e/cey*^** / /tf'efs-eff/S f/eSexyt**.* S f'S/tf'S ScPSS'/'efS S/'t*ec^ Quef team/** (216) 687-8741 Martha J. F riar, Esq. Law Departm ant Union Carbi le Corporation Old RIdgebu ry Road Danbury, Co nnecticut 06817 AUG 71985 |L 1> EWAR Re Neff, Perkins, Sheppard and Whltmer Dear Martha Th e Celanese answers to Interrogatories did not name Union Carbi de as a supplier, of VCi'or pyc to the Hilliard facility* Robinl Weaver spoke to Michael Moore, one" of the plaintiffs1 attorneys, and asked whether the plaintiffs would now dismiss Union Carbi ie from these four cases. Mr. Moore1 s answer was that Celanese at torneys had told him that a document search had not been coraple ted and that Celanese's answers to interrogatories were incora^ lete. Plaintiff has granted Celanese an extension of time until August 19 to produce documents with respect to pur- chases of VI C and PVC. In the meantime, plaintiff has granted us an additional stipulation that we do not have to answer the complaints until after the d ocuraents are produced on the 19th. Presumably, Mr. Moore will examine those documents, inquire of Celanese's attorneys if the y have now completed their document search, and then make a decl slon whether to dismiss Union Carbide. Depending on what Celane se ultimately produces, we may be able to achieve dismissal f rom these cases without filing motions for summary judgment, Mr. Moore seems to be a reasonable fellow who will dismiss tho se defendants who are not implicated by Celanese's records. If you have any questions, please call me. Very truly yours. , , 1/rJM rtXV- Mitchel B. Axler MBA:dms cc: Robin G. Weaver, Esq PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 071328 PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 071329