Document pezREXvr0NNngGoDGDxjpnR8a

4 ? UNION CARBIDE CHEMICALS LAW DEPARTMENT 39 Old Ridgebury Road Danbury, CT 06817-0001 AND PLASTICS COMPANY INC. November 5, 1990 R. N. Wheeler, Jr. 1912 Shady Branch Trail Richmond, Virginia 23233 Re: Alice L. Warren v. Union Carbide, et al. Dear Mr. Wheeler: Union Carbide has been involved in being named as a defendant in a lawsuit involving a fellow who worked for Monsanto in Springfield, Massachusetts, allegedly handling PVC from 1947 to 1987. Unfortunately, he died allegedly due to his exposure to vapors which caused his angiosarcoma of the liver. You may recall that we previously had discussed this case in a conference call with Attorney Lane McGovern and Pierce Cray of Rop s & Gray in Boston. Union Carbide has selected other counsel in place of that firm. Sharon Burger of Nutter, McClennan Fish is handling the matter for Union Carbide. I would appreciate it if you could review the interrogatories that I have enclosed with this letter, along with the production r quests. We have sought an extension of time, and have objected some of the interrogatories. Nevertheless, we need to obtain information which would be of assistance to us in responding to these interrogatories. to I will be working with Dick Wise, who is our Product Safety Manager for PVC. I will also be asking Dottie Von Ehrenberg. our paralegal, to follow up with you in regard to obtaining information which might be of some assistance to you. I will ask her to provide you with a copy of interrogatory and production responses that we have previously submitted in prior lawsuits concerning PVC. If you would be so kind as to review the interrogatory and production requests and provide suggested responses to us by November 27th, I would be very grateful. Of course, we would compensate you for your services in that regard, as per our consultantcy relationship with you. PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 082087 November 5, 1990 Page 2 1 If you have any questions. please feel free to contact me or Dottie Von Ehrenberg. Yours very truly. K Dm*/ John R. Downey JRD/es cc: Sharon R. Burger, Esq. Dottie Von Ehrenberg Betty-Lynn White, Esq. Letter dictated by Mr. Downey; signed and sent in his absence by secretary. privileged and *hp^IJ?|NT,AL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 082088