Document nmevYVxNYrOGj16EnO9VNrOo8

NUTTER, McCLENNEN & FISH ONE INTERNATIONAL PLACE BOSTON, MASSACHUSETTS 02110-2699 617 439-2000 TELEX: 94-0790 TELECOPIER: 617 973-9748 May 23, 1990 18371-1 Mr. Raymond A. Deckert Environmental Claim Technical Assistant Kemper National Insurance Companies Route 22 Long Grove, Illinois 60049-0001 Re: Insured: Union Carbide Claimant: Alice Warren Your FileNo. :555 QN 146005-N Dear Mr. Deckert: Your recent letter to Pierce Cray of Ropes & Gray regarding this matter has been forwarded to me for response. This office now represents Union Carbide Chemicals and Plastics Company, Inc. in this matter, along with two of its co-defendants, Conoco Inc. and The Dow Chemical Company. To bring you up-to-date-on the status of this matter, you should know that discovery has commenced. In particular, the focus has been on product identification at this stage. That is, we have been attempting to determine whether or not plaintiff can establish that vinyl chloride monomer (VCM) distributed by each of the defendants actually found its way to plaintiff's decedent's work place at Monsanto in Springfield, Massachusetts. There has now been some identification of your insured's VCM at that site during the relevant period, but this is not to suggest the plaintiff can or cannot prove her case with the information at hand. Please feel free to call me if you have any further questions at this time. SRB/jIf cc: John R. Downey, Esq. 5178i/31 HYANNIS AMSTERDAM: HOUTHOFF NUTTER McCLENNEN COUNSEL: LONDON TOKYO PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 082213