Document n95Ynd96pqkaDzv6oeVp6nq7X

UNION CARBIDE CHEMICALS AND PLASTICS COMPANY INC. Law Department 39 Old Ridgebury Road Danbury, CT 06817-0001 h0 September 21, 1989 Robert L. Hollingshead, Esq. Pitney, Hardin, Kipp & Szuch 163 Madison Avenue CN 1945 Morristown, NJ 07960-1945 Re: Joan Bernadino, Executrix of Estate of Robert J. Bernadino v. Union Carbide Corporation Dear Mr. Hollingshead: My previous efforts to talk to you over the phone have been unsuccessful. We had discussed possible settlement and/or trial verdict estimates. Would you please provide me with that information? I note that the plaintiff is attempting to consolidate the case with the Peterson case. My own thoughts are that keeping them separate is probably more advantageous to us. Therefore, please oppose the effort to consolidate. Very truly yours, frJUj John R. Downey JRD/els Letter dictated by Mr. Downey; signed and sent in his absence by secretary. PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 07V>1 >> 'H12