Document mBxoEK1Xm72KMB5aB0yQaNgNg

REGINALD H. WOOD Drayden, Wyche & Wood, l.l.p. ATTORNEYS AT LAW 1360 POST OAK BLVD. SUITE 1650 HOUSTON, TEXAS 77056 May 6, 1994 VIA FACSIMILE AND FIRST CLASS MAIL (713) 965*0120 PAX (713) 960-0010 TOLL FREE 800-969-0067 CONFIDENTIAL Gregory Winfree Law Department Union Carbide Chemicals and Plastics Company, Inc. 39 Old Ridgebury Road E-3 Danbury, Connecticut 06817-0001 Theodore J. Theophilos Sidley & Austin 875 Third Avenue New York, New York 10022 Re: Civil Action No. H 94 1101; Dallas Stevenson, Individually and as Representative of the Estate of Elizabeth B. Stevenson, Deceased, Geneva Bolden, Warren A. Stevenson and Susan Coon v. Union Carbide Chemical and Plastics Company, Inc.; In the United States District Court for the Southern District of Texas, Houston Division Civil Action No. H 94 1102; Denice P. Callis, Individually and as Representative of the Estate of Andrew Callisi Deceased, Denice P. callis, as next friend of Adrian Callis and Ariel Callis v. Union Carbide Chemical and Plastics Company, Inc.; In the United States District Court for the Southern District of Texas, Houston Division Civil Action No. H 94 1103; Doris Eirven, Individually and as Representative of the Estate ofRobert H. Eirven, Deceased, Robert Eirven, Jr. and Sheila Eirven v. Union Carbide Chemical and Plastics Company, Inc.; In the United States District Court for the Southern District of Texas, Houston Division Gentlemen: Enclosed is a letter I received from Catherine Baen concerning the above-referenced cases. Of the names mentioned, I have had personal experience with only Tommy Proctor. Mr. Proctor is a defense oriented, 20 year lawyer whose mediation style is primarily to "carry water", but will quickly assess who is in the superior position. It is my opinion that he is an effective mediator. PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 073399 Gregory Winfree Theodore J. Theophilos May 6, 1994 Page 2 To this list I would propose adding the following: Judge Paul Ferguson 2000 Post Oak Blvd., Suite 1900 Houston, Texas 77056 Gary V. McGowan 1 Riverway, Suite 1855 Houston, Texas 77056 Judge Ferguson has mediated numerous cases involving toxic tort/personal injury (primarily asbestos) and Hoechst. He has been very effective and is an advocate of settling the case, if at all possible. His style is very much hands-on. Likewise, Gary McGowan is a very effective mediator. He is a 20 year lawyer and former name partner in Susman, Godfrey & McGowan. Gary left 3-4 years ago to establish a mediation practice. His expertise as a lawyer was commercial litigation and he has an excellent grasp of strategic factors and leverage points which aid in settling a case. Ms. Baen*s letter also indicates a desire to mediate the cases in 60 days. 1 have previously informed Ms. Baen that the cases are not likely to be in a posture that would promote an effective mediation that quickly. Please advise me of your thoughts at your earliest convenience. Sincerely, RHW:je Enclosure c:\ttt\uokjn\fteveiuo\wiiifree.Mr Reginald H. Wood PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 073400