Document eJBK9ed7gD8JLVa7yxQywr6M

JONES DAY 2727 NORTH HARWOOD STREET DALLAS TEXAS 75201 1515 MAILING ADDRESS PO BOX 660623 TELEPHONE 214 220 3939 FACSIMILE 214 969 5100 DALLAS TEXAS 75266 0623 214 969 5134 kellystewart@)onesday com JP131252 skh 049107 130053 December 28 2004 VIA HAND DELIVERY Randall D Collins Esq The Law Offices of Herschel L Hobson 2190 Hamson Avenue Beaumont TX 77701 RECEIVE! DEC 3 0 2004 ft 0Ug -J^cb --- 04_37 Re Holmes etal v Airco etal Supenor Court of New Jersey Law Division L No 001307 04. Burlington County. New Jersey Dear Randall Enclosed are documents Bates labeled OCC 14093 - 20828 (except documents withheld on the basis of privilege) that are being produced as a supplemental production in the above referenced case Also enclosed are privilege logs for OxyChem s original and supplemental productions of documents in this case OxyChem previously produced documents 19 000 through 3419 013 as well as documents OCC 0001 through OCC 14092 m prior cases Documents OCC 14254 14880 were previously produced as OCC 12022 12646 but have been re Bates labeled because of the numbers OCC 12022 12646 were inadvertently used twice in prior productions Documents OCC 15382 15861 are documents that were obtained from PolyOne Corporation We are awaiting receipt from PolyOne slides and/or photographs of the Burlington plant dunng the relevant time period We will produce those as soon as we receive them and have them reproduced As we discussed (and as OxyChem s formal objections note) OxyChem is not producing (1) personnel and medical files for employees other than Mr Holmes (2) personnel monitoring records for Burlington employees other than Mr Holmes (3) personnel and area momtonng records and water and soil testing documents from OxyChem s facility in Hicksville New Jersey (4) post May 1984 (when Mr Holmes ended work at Burlington) sales/supply DU 5892764v 1 ATLANTA RVINE ARIS BE JING BRUSSELS CH CAGO CLEVELAND COLUMBUS LONDON LOS ANGELES MADRID MENLO PARK MILAN ITTSBURGH SAN FRANC SCO SHANGHAI SINGAPORE DALLAS FRANKFURT MUMBAI MUNICH SYDNEY TAIPEI HONG KONG HOUSTON NEW DELHI NEW YORK TOKYO WASH NGTON