Document MoopMqmQQnmVxDVRQ0jG2Y0z

30 KENNEDY PLAZA PROVIDENCE, R. I. 02903 (-401) 621-6400 TELECOPIER: (401) 521-0910 U7 Ropes & Gray ONE INTERNATIONAL PLACE BOSTON, MASSACHUSETTS 02110*2624 (617) 951-7000 TELECOPIER: (617) 951*7050 Writer's Direct Dial Number: (617) 951-7579 January 8, 1990 1001 PENNSYLVANIA AVENUE, N. W. WASHINGTON. D. C. 20004 (202) 626-3900 TELECOPIER: (202) 626*3961 Lawrence A. Looby, Esq The Dow Chemical Company Legal Department 2030 Willard H. Dow Center Midland, MI 48674 John R. Downey, Esq. Union Carbide Chemicals & Plastics Company, Inc. Law Department 39 Old Ridgebury Road Danbury, Connecticut 06817-0001 Judith Elledge, Esq. Conoco Inc. P.0. Box 4783 Houston, TX 77210 Re: Alice Warren, et al v. The Dow Chemical Company, et al Dear Larry, John and Judy: I am enclosing a copy of a letter and its enclosure which I recently received from Mark Granger, Goodrich's counsel. With respect to the question whether any separate Monsanto entity may have supplied Monsanto's Indian Orchard plant in Springfield with vinyl chloride, the Monsanto answers in the Cullinan case stated that "The Springfield plant was also supplied with VC monomer internally from Monsanto's Texas City plant." Perhaps one of your production people would know whether the Texas City plant was at any time in the last 25 years owned or operated by a Monsanto subsidiary rather than by Monsanto itself. If need be, possibly this information can be gleaned from the PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 082362 Ropes & Gray Lawrence A. Looby, Esq. John R. Downey, Esq. Judith Elledge, Esq. -2- January 8, 1990 Moody's or Standard & Poors manuals, which often include information concerning the subsidiaries and plants of major corporations. If you wish, I can have a paralegal check on this. However, each annual volume would have to be checked for the years that we are interested in. I am not sure whether the volumes for the early years will be readily available. Sincerely, / Lane McGovern LM/ DMB: lmquest , dc Enclosure PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 082363