Document V31DzD4jxBKaG9DbGnjV0ndp

ROBERT L. HOLLINQSHEAD DIRECT DIAL NUMBER (201) B3l'ABl7 /if? 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 U1 NEWARK OFFICE 33 WASHINGTON STREET NEWARK, NEW JERSEY 07102 (201) S23 IB0O September 11, 1989 Mr. R. N. Wheeler, Jr. 1912 Shady Branch Trail Richmond, Virginia 23233 Re: Peterson v. Union Carbide Corporation Dear Nick: While in the course of preparing answers to plain tiffs' Supplemental Interrogatories in this case, it came to my attention that we still need to provide additional infor mation in response to the initial Interrogatories that Carbide answered a while ago. Specifically, I am enclosing a copy of my letter to Peter Davey, Esq. dated April 14, 1988 wherein I set forth the answers that required more detail. I would appreciate it if you would review the enclosed to see if you can get any of the information that we need and then call me so we can discuss this further. Sincerely, * ROBERT L. HOLLINGSHEAD RLH/rtd cc: John Downey, Esq. (w/enc.) PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" r.EXVZD SEP ; : J. r. r-..... UCC 088547 m (jsi^ April 14, 198ft Pdtaz 7* Davey, Bsq. Union Carbide Corporation Law Department B-1275 39 Old Ridgebury Road Danbury, CT 06817-0001 Rat Pataraon v. Union Carblda Daar Patari Plaasa nota that wa have sarvad our anawara to plaintiffs' Xntarrogatoriaa, but wa atill bava to prepara more specific anawara to some of thoaa interrogatories. Tha particular Xntarrogatoriaa and ay understanding of what needs to be dona to prepare tba anawara are sat forth below* No. 33* Tbia quaation asks about tba manner of compensation paid to OTD/ATC by Carbide. Wa agreed that you will review tba contract and apeak to Mr* Bowles to obtain tbia information* Nqa. 38, 39 and 40. Tbia question asks for information about tba labels on tba containers. Please obtain sample labels from the time period of 1960 to 1977. xf labels are not available, than wa should obtain the information requested from other sources, a.q.. present or former employees* No. 43. Wa stated in tha answer that wa will attempt to compile a list of persons who ware in charge of research on PVC and who are still employed at Carbide. To assist you on this, please note that in the Mallho cas wa listed tha following chemistsi PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 088548 Pater P. Dav y, Beq. April 14, 1988 Page Two R.J# Hanna D.E# Richardson H.M# Rife J.P. Erdmann D.l. Hngie R.A. Neither J.A, Biddle T.L. Dawson D.R# Montgomery J.J. BrasinsJci C.J. Baines W.B. Whitehurst No# 46# Bven though we have answered this question regarding your insurance coverage, 1 think you should ask Ed Dehoughy the amount of liability insurance coverage and the insurance company# X have the information in other cases, but X am concerned that it may not be accurate for the time span in this case, ie#, 1960 to 1977. No# 52* We stated in this answer that recommendations as to protective clothing were contained on Material Safety Data Sheets, which would be supplied# Please collect the available MSDS's (or any product information sheets which may have preceded the use of MSDS's) and provide them to me# No# 94# We stated in the answer that we will supply a list of Medical Directors# Please attend to this# No# 145# This question requests additional insurance information, which should be obtained from Ed DeLoughy# xf you have any questions concerning the above, please call me. Sincerely, RLHljs cci R.N# wheeler ROBERT L. HOLLXMOSBBAD PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 088549