Document MGdDBgg5MmQb9MmNGz8zOpKxa

CHICAGO LOS ANGBI.ES WASHINGTON, D.C. WRITER'S DtasCT NUMBER (212) 906*2380 Sidley 8c Austinr A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 875 Ttttrd Avenue New York, New York 10022 Telephone 212: 906-2000 Telex 97-1Q96 Facsimile 212: 06-2021 125* Anitfvfciafy 1866-1991 January 31, 1995 7 LONDON SINGAPORE TOKYO Gregory D. winfree. Esq. Union Carbide Law Dept. 39 Old Ridgebury Road Danbury, CT 06817-0001 E3-282 Re: Overstreet v. UCC Dear Greg: Enclosed are the Notices of Deposition which have been filed in the above-captioned case. X have not yet determined who these individuals are. Please call me at your earliest convenience to further discuss this matter. Sincerely,- TJT/sr Enclosures Theodore J. Theophilos t B B W !5 _ \ <y ; lJU FFB -3(995 ! PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 074106 T.os ANfvr.r.rs View YORK VASHINOTOS', u.c, VJUTIBN Dl*ECTVl`-<** <315 13*4714 Sidley & Austin" l'\RTK(lll>IIU> IVCUDIVO nortUI9!>`AL CORKMUIlU^t Onu Fntvr National Pla^a Ckzcago. Izxixois oao.`j TexxrilOJfE 012: 803*7000 TEX23C 25*4304 FaCSXXXZX 312: 853*7030 roUNDED 1800 December 2, 1994 K>e> Coding C& r.OKTJON MNOAfORE TOKYO VIA TIPBAL EIPREflfl Barbara L. Johnson wickliff s Hall, P.c. 1000 Louisiana Suite 5400 Houston, Texas 77002 Re: Overstreet v. Dov Chemical Company and Union Carbide Corporation Dear Barbara: Enclosed are original copies of the notices of removal (state and federal) for the Overstreet case to be filed and served on Monday, December 5. Several final steps need to be taken before these papers are ready to be filed, hovever: 1. Dov chemical has not formally retained counsel to handle this case. Because Walter Conrad at Baker i Botbs has handled much of their litigation in the past, I have tentatively drafted these papers vith Baker 6 Botts identified as Dow's counsel. We will know by Monday who will be handling the case for Dov and any necessary changes can be made at that time (a computer disk containing each of these documents is included for this purpose) . In any event, both you and Dow Chemical's attorney will need to sign the final documents; 2 - I will fax to yon on Monday a copy of proof of service on Dow which needs to be included with the other materials already in Exhibit B; 3. We need to obtain a copy of the docket sheet in the Brazoria County action and attach it as Exhibit C; and PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 074107