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UNION CARBIDE CORPORATION 39oldridgebuhyroad,danbury,ctobbi7-000\/
LAW DEPARTMENT
R bert Holllngshead, Esq.
Pitney, Hardin, Kipp & Szuch 163 Madison Avenue Morristown, NJ 07960-1945
Re: Peterson v. Union Carbide Corporation
D ar Bob:
This letter Is the official notification that the above-referenced case has once again been reassigned. John Downey has recently joined our ranks as inside counsel and will b handling all the PVC/VC cases for Union Carbide (soon to be
Union Carbide Chemicals and Plastics Company, Inc.). I have ask d John to make sure that our files on PVC are as complete as possible and that we begin the process of establishing what n eds to be done in the future to assure ourselves we have the n c ssary testimony and document retrieval capability to defend th se kinds of cases In the future. Your suggestions on memorializing Nick Wheeler, etc. will be most welcome to us.
As a result of our last communication, I have not done
anything further on the discovery requests pending until you
ar able to Identify what has not been responded to in previous
allied cases.
#
By copy of this letter I am forwarding the dlcovery papers to John and ask that he call you directly.
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If I can be of any further assistance, feel free to call.
Sincerely yqurs, \
f\ t
Bett ty -j.y^ri. Whi te
BLW:ce 06S8R
cc: J. R. Downey T. W. Reitz D. vonEhrenberg
PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE
ORDER"
bcc: R. P. Lawlor
UCC 088720