Document g2BDjdKB47e4Ey08g8Rm07G1J

H? NUTTER, McCLENNEN & FISH ONE INTERNATIONAL PLACE BOSTON, MASSACHUSETTS 02110-2699 TELEPHONE: 617 439-2000 FACSIMILE: 617 973-9748 January 30, 1991 18371-1 DIRECT DIAL NUMBER: (617) 439-2460 John R. Downey, Esq. Union Carbide Chemicals and Plastics Company, Law Department 39 Old Ridgebury Road Danbury, CT 06817-0001 Inc. Judith Elledge, Esq. Conoco Inc. 600 North Derry Ashford P.O. Box 2197 Houston, Texas 77252-2197 Mary Sundt, Esq. The Dow Chemical Company D30 Willard H. Dow Center Midland, Michigan 48674 Re: Alice L. Warren, Administratrix v. The Dow Chemical Company. Union Carbide, et al Dear John, Judy and Mary: I enclose a copy of the lates reflecting the following depositi February 25. 1991: 10:00 a.m. 1:00 p.m. 3:00 p.m. Larry Gormally Joseph Tierney Jerry Nolet February 26, 1991: 10:00 a.m. 1:00 p.m. 3:00 p.m. Lucy Konieczny Robert Bourget Keeper of Records Monsanto Chemical Company privileged and "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" '''Ff'nyp) HYANNIS, MASSACHUSETTS COUNSEL: AMSTERDAM LONDON TOKYO UCC 081586 NUTTER, McCLENNEN 8c FISH John R. Downey, Esq. Judith Elledge, Esq. Mary Sundt, Esq. January 30, 1991 Page 2 Also, I enc ch Company, Inc.'s Motion for Enlargement of Time served by Joe Rendini last week. I do not recall who all of the individual deponents are. I shall look back over the 30(b)(6) deposition of Monsanto and Ruth Griffith's deposition to figure out who these people are, and I shall then let you know. This is a very ambitious deposition schedule. I can only assume that Keith Minoff believes he is unlikely to obtain much information from any of these people, but feels the necessity to depose them, nevertheless. Once determining who they are, I anticipate attempting to make contact with these individuals to explore, before their depositions, what information and documents they may have. Perhaps this is where Monsanto's counsel could assist in our efforts, and I anticipate approaching him about this. Best regards. Very truly yours, SRB/jlf enclosure cc: Ms. Yolanda Jackson (File No. H105L-76-034969) UCC 081587