Document rxaEeaEzOr7enBdKXre7yyqJG

-x .. ismiiffm. A PARTNERSHIP INCLUDIN3 PROFESSIONAL CORPORATIONS OMOAMH* ix'rf. anV^iih. WACHMCTON, D.C. WA.*mi.Vl>TUN, JAU LOC ANGfLf* 1 lajs0* (Z]S)WXM February 1\ 1995 'OMMi UNOAPORS tontn TOKYO VIA FACSIMILE Gregory D. Winfree. Esq. Union Carbide Corporation Law Department 39 Old Ridgcbuiy Road Danbui y, Conn. 06S17-0001 Rc; Erven v. UCC&P Dev Crcg: I am sending you, under separate cover, the case analysis material for the Eirven matter. As we discussed, Dr. Weir and Dr. Golden will be meeting next week with Karen Myers, Perihan Yalcinkaya, et el. to get them up to speed on the expert issues in the case. Scott Solberg will be there on February 8th and I will join them, on February 9th. (Unfortunately I have oral argument in a matter which the court rescheduled for February Xth -- so I will mix* the first day.) I will be speaking with Karen Myers to confirm the agenda, but they will be meeting with Bob Frantz, Kari Teague, Regina Davis, Boh Arnold and Dnn Weekes so that wc can develop the industrial hygiene defense 1 -arer in the week, Scott will complete the witness interviews of the Carbide employee* whom Plaintiffs have identified. Starling on Sunday, February 12th, we will begin to take the depositions of the plaintiffs* experts (Legator, Dement and Gardner). In addition, on February 14, wc aic tentatively scheduled to depose the individuals (ex-Carbide employees) upon whom plaintiflV experts are relying for data and exposure information. TIuoukIi Di. Golden, we have located a few potentially excellent testifying experts. T hope to complete my initial interviews of these expens by February 17th so that we can identify them on February 20th. In that regard, 1 would tike to arrange a telephone conference call with Dr. Tela, Dr. Gulden and myselfto discuss the epidemiology issues in the ease. Should I call Dr. PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 073206 hinr.KY ft Ai.stin fircgmy D. WinfrM, E*q. February i, iyys Page 2 Nkw Youii Teta directly or could you schedule the conference can? I would like co speak with Dr. Teta in advance to discuss the suuus of the litigation. I also need to meet with the Carbide representatives in Danbury whom we may want to call pertaining to the corporate efforts toward safety and high standards legal ding industrial hygiene. Could you suggest a time that might be appropriate, finally, we have not addressed the issue of documents icgarding vinyl chloride which may exist at the corporate level. How should we go about gelling a handle on those materials. Please give me a call after you have reviewed this letter. Tn7.tr cc: Karen Myers (w/tend.) Scuu C. Solbcri Esq. (w/end.) Nathan P. Eimcr. Esq. (w/q end.) ophilos UCC9MNLU1W O'!*) Jttpffl) PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 073207