Document nNbjk70vkjJgna4eX5BnNDwvG
CHICAGO WASHINGTON, D.C. LOS ANGELES
WRITER'S'OIRECT MUHBBI
SIDLEY & AUSTIN
A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS
875 Third Avenue New York, New York 10022 Telephone 212: 906-2000
Telex 97-1696 Facsimile 212:906-2021
125th
AnnJvomary 1066-1 Ml
FACSIMILE TRANSMITTAL TOTAL PAGES (INCLUDING COVER SHEET):
DATE: January 12, 1995
4
TO: FAX #:
FROM:
Gregory*' D. Win free" 1 *'*'* Union Carbide Corporation 9120379462S9
Theodore J. Theophilos SIDLEY & AUSTIN NY 212-906-2380
SUBJECT: COMMENTS:
IF THIS FAX IS UNCLEAR OR INCOMPLETE, PLEASE CONTACT Theodore J, Theophilos AT 212-906-2380.
LONDON SINGAPORE
TOKYO
PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE
ORDER"
This message is intends only for neusi ofthi hoivoualor entity to which it i* addressed afc wlycontwn information that ib nwLiese, confidential ano om*rt from dcceasum uHon afwlicails law. If te reader of thb message s not the
NTMB REOnENTON THE EMPLOYEE OH AOBJ7 RESFONSBLE FOR DEUVRNG THE NEl SAGE TO THE MTBGCD RECPENT YOU AM HEREBY NOTVIED THAT ANY aSSEMRA'nON. TRHU7IQN OR COFYWQ OF TW COMMUNICATION IS STRICTLY PROMOTED. IF YOU HAVE RECEIVED TW COMMUNICATION CMtOR PUASE NOTVY US MMCOUTELY V TUIF+40NE AND HFTVIRN THE ORIGKAL MESSAGE TO JS AT THE ABOVE
aooresb via the U.S. Postal Service. Thank you.
UCC 073251
MEMORANDUM
VIA POUCH,, FAX. STARMAIL
TO:
Gary W. Jacob
FROK:
Theodore J. Theophilos
RE t
Eirven v. UCC&P
DATE:
January 6, 1995
t i f ! OSO
CO
PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE
ORDER"
Tim Kapshandy suggested that I speak with you directly. I need to get all available information regarding the following experts who have been designated by the plaintiffs in the above-
captioned case: -
John M. Dement, Ph-D., CIH Duke University Medical Center Division of Occupational and Environmental
Box 2914 Durham, North Carolina 27710 (913) 286-3232 Subject Matter: State of the Art
Medicine
Dr. Frank H. Gardner 7602 Beluche Drive Galveston, Texas 77551 (409) 744-4924 Subject Matter: Hematology
Dr. Marvin LeGater University of Texas Medical Branch
2.102 Ewing Hall, 700 Strand Galveston, Texas 77555 (409) 772-1803 Subject Matter: Toxicology; the genetic
vinyl chloride exposure
effects
of
In addition to any deposition or materials that Sidley & Austin has on these three gentlemen, I would appreciate it if
you would do IDL and IDX searches for them. Any charges should be billed to 91444/45390.
Tim mentioned that there was some material regarding
Mr. Dement's resume. I would appreciate it if you could also make sure that I receive that material. Thank you very much for
your help. Please call me if you have any questions.
cc:
Tim Kapshandy Gregory W. Winfree, Esq.
TJTftAll.SUN (l/6/y3 11:30am)
UCC 073252