Document OzRNjXRj1Lv9d6OBZp7bZrJ6w

Christopher M. DiMuro Direct Dial: 973-639-7295 christopher.dimuro@lw.coni LATHAM&WATKINSllp March 2, 2004 VIA FIRST CLASS MAIL Mark R. Cuker, Esq. Williams, Cuker & Berezofsky 51 Haddonfield Road, Suite 160 Cherry Hill, New Jersey 08002 One Newark Center, 16th Floor Newark, New Jersey 07101-3174 Tel: (973) 639-1234 Fax: (973) 639-7298 www.lw.com FIRM / AFFILIATE OFFICES Boston New Jersey Brussels New York Chicago Northern Virginia Frankfurt Orange County Hamburg Paris Hong Kong San Diego London San Francisco Los Angeles Silicon Valley Milan Singapore Moscow Tokyo Washington, D C. MAH 9 - Re: Lewis v. Arico Inc., et al. Docket No. L-10503-02 (Essex County. NJ1 Dear Mark: Enclosed for production in the above referenced cause are documents bearing production numbers ST503-0000001 through 0000023 and ST503 0000025-0000036. Please note that due to a clerical error ST503-0000024 was numbered, but is not responsive to any request. ST503-0000001-0000013 are responsive to requests 4 and 5. ST503-0000014-0000016 are responsive to requests 4, 5 and 6. It is our understanding from Shintech, that the language about the hazards of PVC embedded in these bills of lading is representative of what appeared on all bills of lading sent to customers in 1982 (the only year for which Shintech has any record of any kind for sale of PVC to Pantasote's Passaic, New Jersey plant during the period set for the in the document request). ST503-0000017-0000023 are responsive to request 4 and 5. ST503-0000025-0000026 (MSDS sheets) are only being produced as samples of the MSDS sheets that were available at Shintech in the time periods that they represent. Very truly yours, Enclosures Christopher M. DiMuro of LATHAM & WATKINS LLP