Document M45nwrReKbQwj78nMmvY9JOGa

UNION CAI BIDE CORPORATION 33 OLD ODGEBURY HOAD. DANBURY, CT 0601 Corporate Mealcr. lefety and Environmental Affairs Department September 3, 1985 Mitchel B. Axl r Esq. Squire, Sander; 4 Dempsey Counsellors at Law 1800 Huntingtoi Building Cleveland, Ohi > 44115 ieff, Perkins, Sheppard and Whitmer request. attaching the affidavit signed and notarized as per your Very truly yours. RNW,Jr./maw Attachment R. N. Wheeler, Jr. 0521G PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" received SEP 1 0 1985 M. J. FRIAR ucc 071320 COUNTY OF K "AWHA STATE OF WES VIRGINIA AFFIDAVIT OF R. NICHOLAS WHEELER, JR. 1. . NICHOLAS WHEELER, JR., being duly sworn according to law, depose and S Ly: 1. My business address is P. 0. Box 8361, South Charleston, WV 25303 .2 I am employed by the Union Carbide Corporation. My title Is Assistant D1 rector of Product Safety. 3. To enable Union Carbide Corporation to determine whether It made any sales of polyvinyl chloride resin to defendant Celanese Corporation, Celanese PI antics, or Celanese Piping System at its Hilliard facility in Franklin Col ity, Ohio or at any location in Columbus, Ohio, a systematic search of Unf on Carbide Corporation's Sales Accounting Records for the years 1965 through 1982 was undertaken at ny direction. 4. I have reviewed these Sales Accounting Records for the years 1965 through 1982 The records contained no Indication whatsoever of any sale of polyvinyl cn orlde resins to Celanese Corporation, to Celanese Plastics, or to Celanese Pldl ng Systems at any location In Columbus, Ohio or in Hilliard, Ohio during the > ears specified. UCC 071321 o Sworn to before me and subscribed in my presence this ^3 st^L day of September, 1985. V d. lotary Publ -2- UCC 071322