Document YDR6yjN3z7zNEqgNyoKxpogk

V RECEIVED * MAY 10 1985 N* .Wheelerj Jr* UNION CARBIDE CORPORATION OLD RIOGEBURY ROAD. DANBURY. CT. 06817 LAW DEPARTMENT VIA EMERY May 8, 1985 Mitch Axler, Esquire Squire, Sanders & Dempsey 1800 Union Commercial Building Cleveland, Ohio 44115 Re: Herman A. Dendinger. et al. v. Chrysler Plastic Products Corporation, et al., including Union Carbide Corporation U.S. District Court, Northern District of Ohio, Western Division Docket No. 84-7854 _____ _ Dear Mitch: Pursuant to our telephone conversation on today's date, I enclose a copy of the summons and first amended complaint in the abovecaptioned action. The Corporation was served on May 6, 1985 by certified mail and we have twenty (20) days to answer, or by May 27, 1985. Plaintiff was an employee of Chrysler Plastic Products Corporation in Sandusky, Ohio and alleges he was exposed to polyvinyl chloride resin and vinyl chloride monomer from August 9, 1968 to October, 1980 causing serious physical injuries, including cancer and associated pathologies. He has sued ten PVC resin manufacturers. By copy of this letter to Nick Wheeler, I would ask him to check the Corporation's sales records for sales to Chrysler in Sandusky, Ohio from 1968 to 1980. The plaintiff is seeking $11,500,000 compensatory damages and $10,000,000 punitive damages. We have discussed the fact that Union Carbide may want to sub stitute counsel, if we discover we were a supplier to Chrysler, and join other defendants in a single law firm joint defense effort. The law firm of Fuller & Henry in Toledo, Ohio has been recommended by Diamond Shamrock Corporation and B. F. Goodrich Company. I look forward to working with you on another case. Very truly yours, MJFrmh Enclosure Martha J. Friar ucc 043326 Mitch Axler, Esquire May 8, 1985 Page 2 cc: R. A. Butler - E3-262 (without enclosure) L. A. Crisorio - P2-608 (with enclosure) E. D. DeLoughy - B4-155 (with enclosure) - Please notify insurers. J. F. Skislock - D2-241 (without enclosure) C. E. Van Dyk - E2-289 (with data sheet) - Please add this new case to your list of polyvinyl chloride cases. R. - South Charleston (with enclosure) ucc 043927