Document mBDbZJZKLzX6ZmRdGmn3K2jg0
Pitney, Hardin, Kipp & Szuch
(MAIL TO)
P. O. BOX 1945 MORRISTOWN, NEW JERSEY 07962-1945
JQ4S 7/ Co
Gregory D. Winfree, Esq. Litigation Counsel Union Carbide Corporation Law Department 39 Old Ridgebury Road Danbury, CT 06817-0001
Re: Colbv v. Union Carbide Corporation
Dear Greg:
Please be advised that this matter has been a:s signed a trial date of November 8, 1993, which I consider to| be a r slatively firm date. As you know, we have completed the! depos tions of plaintiff's liability experts and are scheduled t comjblete the depositions of . the treating physicians this month;. We Expect to provide our expert reports to plaintiff in th begi nning of October.
I believe that we should schedule a meeting in the near future to discuss plaintiff's settlement demands a id trial preparation. I will call you in the next few days to dis russ this and, if you agree, to arrange a convenient date for the neeting.
Sincerely,
RLH:pc
ROBERT L. H0LLINGSSEAD
PRIVILEGED AND
"CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE
ORDER"
U CC 075717