Document qmRe2Y8Rb89BgLzLY0oK2dMek

i*ln/SL ROBERT A. BUNDA 5 /? flU RC Fu'ller & Henry 1200 EDISON PLAZA P. O. BOX 2068 TOLEDO. OHIO 43603 4>i tas ltto TCL.KX Vi* WUI **0-*? S*l5 TtLtCOPIK" June 9, 1986 L^Vffi i! ' > - -- Is. L P. F. MVEY PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" Peter F. Davey, Esq. Union Carbide Corporation 39 Old Ridgebury Road Danberry, Connecticut 06817-0001 Re: Dendinger v. Chrysler Plastic Products Corporation, et al.i Wallace v. Chrysler Plastic Products Corporation, et al. Dear Mr. Davey: This letter is to follow-up on our conversation of June 9 concerning questions I had about the sales by Union Carbide of PVC material to Chrysler Plastic Products. In the enclosure to your letter to me which was prepared by Mr. Wheeler, I note that in 1972 Mr. Wheeler indicates that suspension PVC homopolymer in the amount of 40,500 lbs. was sold to Chrysler in November and a nearly like amount in December. I have not seen any figures as to the amount of PVC used by Chrysler Plastic Products at its plant, and wonder whether anyone at Union Carbide can give me an idea as to the normal shipment of PVC to a plant of this size. I understand from the context of Mr. Wheeler's memorandum that this amount is small and constitutes a "trial run". This is not apparent to one not familiar with the industry practice, however, and if I'm to convince plaintiff's attorney that this is a small amount of product, I need more information to put the 40,500 lbs. in perspective. If necessary, I can probably obtain this information from Chrysler, but I thought I would approach you first for any help you may be able to provide in this regard. Also, it is indicated in Mr. Wheeler's May 10, 1985 memorandum that in 1973 non-solvent (PVC) copolymer VYNW-5 and solution vinyl (PVC) VYHB were sold to Chrysler. In subsequent years, it is indicated that non-solvent copolymer VYNW-5 and ucc 043671 Fuller & Henry TOCCOO, OHIO Peter F. Davey, Esq. -2- June 9, 1986 / solution vinyl VYHH were sold. Does the lack of an indication of (PVC) in connection with those later years indicate that no PVC material was contained in those products, as opposed to the 1973 sales? I presume the answer to this is yes, but I would like confirmation. I also presume that flexol plasticizers contained no PVC material, but I would like confirmation of this, as well. I apologize for the lack of chemistry background which these questions may exhibit, but any information you can provide to this poor layman would be appreciated, especially since my ignorance about chemicals is at least matched, if not exceeded, by that of plaintiff's counsel. 1, too, have an educational task before me when I try to convince him to dismiss Union Carbide based upon this information, and any assistance you can provide will be appreciated. RAB/mh 3861-1 3861-2 PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER"