Document O37zK7ZaKp08mBDJVOkpw4BGX

ROBERT L. HOLLINGSHEAD OIRECT DIAL NUMBER (201) 63MBI7 Pitney, Hardin, Kipp & Szuch 163 MADISON AVENUE P. O. BOX 1945 MORRISTOWN, NEW JERSEY 07960-1945 MORRISTOWN (201)267-3333 NEW YORK (212) 926-0331 TELEX 642014 TELECOPIER (201) 267-3727 L~* / Y UCC Newark orrice 33 WASHINGTON STREET NEWARK. NEW JERSEY 07102 (201)623-1960 August 17, 1989 John Downey, Esq. Union Carbide Corporation Law Department E3-285 39 Old Ridgebury Road Danbury, CT 06817-0001 Re: Joan Bernadino, Executrix of the Estate of Robert J. Bernadino v. Union Carbide Corporation_______ Dear John: This will acknowledge receipt of your letter of August 3, 1989, together with copies of the Summons and Complaint in this action. Of course, we will be pleased to defend the interests of Union Carbide in this matter .- Please be advised- that the answer to the Complaint will be due on September 5, 1989 . I will send you a draft of same for your review during the preceding week. Kindly note that Betsy Weiss, Esq., will assist me in this case. Betsy's current hourly rate is $135. Any paralegal time spent on this file will be no higher than $75.00 per hour. As we have discussed, it is my intention to file a motion to consolidate this action with the Peterson case. PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" RECEIVED AUG 2 1 1989 J, R. DOWNEY * r ucc 075217 h'lTNEY, Hardin, Kipp & Szuch John Downey, Esq. August 17, 1989 Page 2 which also involves an employee's exposure to PVC and other chemicals at the Amboy Terminaling Company in Perth Amboy, New Jersey. Additionally, the plaintiffs in both cases are represented by the same attorney. Thank you for requesting us to represent Union Carbide in this matter. Betsy and I are looking forward to working with you once again. Sincerely, RLH:Ih cc: R.C. Wise ROBERT L. HOLLINGSHEAD PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 075218