Document YGLNK6KRGgexBQVBZ1ZoqeyY0

MILTON J DONOVAN JOHN H MADDEN. JR. EDWARD J. BARRY GORDON H. WENTWORTH JAMES H TOURTELOTTE CHARLES K. BEROIN. JR VICTOR ROSENBERG RONALD C. KIDD JEFFREY W ROBERTS JEFFREY L MeCORMICK JAMES M RABBlTT JAMES F MARTIN ROBERT P CUNNINGHAM JOHN C SIKORSKI i ROBINSON DONOVAN MADDEN & BARRY, P. C. ATTORNEYS AT LAW 1500 MAIN STREET -- SUITE 1400 POST OFFICE BOX 15609 SPRINGFIELD. MASSACHUSETTS 01 1 15 (413) 732-2301 TELECOPIER No, (413) 735-4656 November 8, 1989 PAUL S WEINBERG HOWARD A, KOSKI NANCY FRANKEL PELLETIER PETER R, JOHNSON HENRY C CROPSEY FREDERICA C McCARTHY JAMES O'S MORTON NEVA I. KAUFMAN DOUGLAS F BOYD KEITHA MINOFF JAMES K BODURTHA HOMANS ROBINSON 1094-1073 LAWRENCE M. SINCLAIR 1942-1906 John bowney, Esq. Law Department E3 Union Carbide 39 Old Ridgebury Road Danbury, CT 06810 Re: Estate of John H. Warren v. Union Carbide, et als Dear Mr. Downey: As you requested, I am enclosing with this letter certain data concerning John H. Warren. I will describe each document and what we think it means hereinafter. I do want to give you an overview first. John Warren was born on September 14, 1923. He did not smoke or drink. He was employed by Monsanto from May 12, 1947 through May 30, 1987. He was married to Alice Louise Eaton on June 5, 1948. They had two (2) children, Daniel Warren born 11/14/53, who lived with his mother and father until his father's death, and John David Warren born 4/9/52 who is married and the father of a six (6) year old daughter. Heather, who was close to her grandfather. The claimants in any action would then be Alice Louise Warren who is 61 years old, Daniel Warren, John David Warren. John Warren was exposed to vinyl chloride from 1948 to 1975 inclusive. He became ill on May 30, 1987. He died on January 29, 1988 at age 64. Monsanto records show that he worked UCC 082408 ,p.C. f ft 0ABBv jo DONOVAN < MADDEN. JR WARD J BARRY HDON H, WENTWORTH 4ESH TOURTEUOTTE RLE5K BERGIN, JR 'OR ROSENBERG AL.D C KlOD REV W ROBERTS REV L MeCORMlCK S M RABBITT F MARTIN <T P CUNNINGHAM 5IKORSKI ROBINSON DONOVAN MADDEN St BARRY, P, C ATTORNEYS AT LAW 1500 MAIN STREET -- SUITE MOO POST OFFICE BOX 15609 SPRINGFIELD, MASSACHUSETTS 01115 (413) 732-2301 TELECOPIER No- (413) 785-4650 Mr. Downey November 8, 1989 page 2 PAUL S WEINBERG HOWARD A KOSKI NANCV FRANKEL PELLETIER PETER R JOHNSON HENRY C. CROPSEY FREDERICA C MCCARTHY JAMES O'S MORTON NEVA I. KAUFMAN DOUGLAS F BOYD KEITH A, MINOFF JAMES K. BODURTHA HOMANS ROBINSON 1894-1973 LAWRENCE M. SINCLAIR 1942-1988 continuously and daily with vinyl chloride between 1948 and 1975. As is verified by the medical records, he contracted angiosarcoma and died horribly after unabated suffering as a result thereof. I am enclosing Dr. Flatow's record to me dated May 3, 1988 which gives a good overview of Mr, Warren's decline. Also enclosed are the Baystate Medical Center Admission record of j/l/87 documenting the onset on 5/30/87, and Baystate Medical enter record of January 1, 1988 through January 29, 1988 which ocuments his last suffering. While I am sure you are familiar Ith vinyl chloride and its link to angiosarcoma I am enclosing e March 11, 1974 National Institute for Occupational Safety d Health Report and "Vinylchloride: A Review" from the jrnal of Social and Occupational Medicine. Please note that early as 1961 Dow noted liver damage from vinyl chloride. . Warren's marriage certificate is enclosed. Finally, I e also enclosed the Agreement for Redeeming Liabiity by Lump which Mrs. Warren entered into with Monsanto. You will ! that Monsanto has given up any claim on the $192,500 it paid as a commutation of Mr. Warren's dependency rights uant to the Massachusetts statute. An additional $35,000 :>aid to Mrs. Warren for her loss of consortium. That e is not, of course, any indication of the value of her . It was only meant to be a nominal payment of the legal Monsanto might expect to incur in a successful defense MILTON J, DONOVAN JOHN H. MADDEN, JR EDWARD J, BARRY GORDON H, WENTWORTH JAMES H. TOURTELOTTE CHARLES K BERGIN. JR VICTOR ROSENBERG RONALD C KIDD JEFFREY W ROBERTS JEFFREY L, McCORMICK JAMES M RABBITT JAMES F MARTIN ROBERT P CUNNINGHAM JOHN C, SIKORSKI ROBINSON DONOVAN MADDEN 6c BARRY, P. C. ATTORNEYS AT LAW 1500 MAIN STREET -- SUITE 1400 POST OFFICE BOX 15609 SPRINGFIELD. MASSACHUSETTS 01115 (413) 732-2301 TELECOPIER No. (413) 785-4656 Mr * Downey November 8, 1989 page 4 PAUL S WEINBERG HOWARD A, KOSKI NANCY FRANKEL PELLETIER PETER R JOHNSON HENRY C CROPSEY FREDERICA C, MCCARTHY JAMES O'S MORTON NEVA 1 KAUFMAN DOUGLAS F, BOYD KEITH A, MINOFF JAMES K, BODURTHA HOMANS ROBINSON 1394-1973 LAWRENCE M SINCLAIR 1942-1986 for all damages as well as jointly responsible. Of course, there can be only one recovery. If all manufacturers were before the Court the damages would be divided among them equally. JHT/gg/5827E Enclosure C: \ Ucc 082410