Document pp7d1YeZjwOaZovJBKynKe937
8/19/83 - c: R. A. Butler
Jackson, Kelly, Holt & O'Farrell
Attorneys at Law P. O. BOA SS3
Charleston, West Vtbginia 863sa
1900 ONE VALLEY SOUARE
TELEPHONE (304) 347-7900
TELECOPIER Gl (304) 340-9149 TELECOPIER Gil-Ill (304) 347-7360
WRITER'S DIRECT DIAL NO. (304) 347-7
August 18, 1983
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610 MONQNOAMCLA tlllLOlNQ
a o. box eio
MORGANTOWN, WCIT VlNtJfNlA 20007
TKLKBNQNE (30A) 0-73M TCLCCOAICN (104) 202-7310
R ECE I VE0 i - i (983 o Tr?(D/]T
Gary J. Triplett, Esquire Union Carbide Corporation 437 MacCorkle Avenue South Charleston, West Virginia 25303
Stevens v. UCC & FMC
Dear Joe:
The plaintiff's videotape deposition de bene esse was taken on Thursday, August 11 and except for the video, was primarily a replay of the deposition taken before this suit was instituted. It was obvious that the plaintiffs' strategy was simply to record his physical condition on tape at the present time. The plaintiff, while looking obviously very ill, did not overplay his hand and so I do not believe that the deposition will be as damaging as his attorneys felt.
My kindest regards.
WTS/ac
RtCi vD
AUG 9 ; 1983
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PRIVILEGED AND
asrsasft
ORDER
UCC 097890