Document oDrR7x2xXK0BgdDorXD7yeVJD

Husch & Eppenberger Attorneys and Counselors at Law too N. Broadway Suite 1300 St. Louis. Missouri 63102 tax: 314-421 0239 314 421 4800 October 16, 1997 VIA FEDERAL EXPRESS Wells T. Watson, Esq. BAGGETT, McCALL & BURGESS P.O. Box 7820 3006 Country Club Road Lake Charles, LA 70606 RE: Ross, et al. v. Conoco, et al., 90-4837 Dear Hr. Watson: We recently obtained closed files from Olin's outside counsel in litigation closed some twelve years ago. From those files, we are making a small supplemental production of documents, bates numbered OLI 4865 through OLI 6182 (copies enclosed). The bulk of this supplemental production, OLI 5364 5790 and OLI 5812 - 5815, is the "Draft Final Report" of Foster D. Snell, Inc., Contract No. L/A 74-167, which apparently was filed in the OSHA record on or about September 13, 1974, as part of the vinyl chloride hearings. The remainder of the production consists primarily of memos relating to monitoring at Olin's Assonet, Massachusetts plant in 1974, in efforts to comply with the emergency vinyl chloride standard. There is some duplication of documents previously produced. We reiterate our statement made in Ms. Bermel's letter of April 7, 1997, that raw monitoring data (including area, personnel and perimeter monitoring) and memoranda regarding employee notifications of monitoring results have not been bates numbered or produced as a result of Mr. Baggett/ Jr.'s statements that plaintiffs do not want copies of such records. Very truly yours. STL-591270.01 Kanm City Jtfftnon Cay SprhtrftU OvHamt fork Wlcbaa tkorla Husch Sc Eppenberger Attorneys and Counselors at Law 100 N. Broadway Suite 1300 St. Louis, Missouri 63103 fax: 314 431 0239 314-421-4800 Wells T. Watson/ Esq. October 16, 1997 Page 2 cc: All counsel of record w/out, ends. Case Master A.R. Johnson IV/ Esq./ w/out ends. STL-591270.01 StlOUiM OtmUmd Park Ptoria