Document x5bG2Jzdy7Rzm6DqJoya4gegm

I NUTTER, McCLENNEN & FISH ONE INTERNATIONAL PLACE BOSTON, MASSACHUSETTS 1)2110-'699 TELEPHONE: 617 439-2000 FACSIMILE, 617 973-9748 March 3, 1992 18371-1 DIRECT DIA1 NUMBER (617) 439-2460 John R. Downey, Esq. Union Carbide Chemicals Law Department 39 Old Ridgebury Road Danbury, CT 06817-0001 and Plastics Company, Inc. Judith Elledge, Esq. Conoco Inc. 600 North Derry Ashford P.O. Box 2197 Houston, Texas 77252-2197 Mary Sundt, Esq. The Dow Chemical Company D30 Willard H. Dow Center Midland, Michigan 48674 Re: Alice L. Warren, Administratrix v. The Dow Chemical Company, Union Carbide, et al Dear John, Judy and Mary: B. F. Goodrich Company is at it again! I enclose a copy of its Opposition to Joint Motion to Dismiss Pursuant to Federal Rules of Civil Procedure. I plan to take no further acrion on this issue at this point. At worst, the Court might deny the joint motion to dismiss without prejudice. However, the Court is well aware through meetings with counsel that plaintiff does not consider the evidence against Conoco or Union Carbide sufficient to warrant plaintiff's continued pursuit of these defendants. PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" HYANNIS, MASSACHUSETTS COUNSEL: AMSTERDAM LONDON TOKYO ' nn\*tr" i !" i * ' : UCC 080799 NUTTER. McCLENNEN & FISH John R. Downey, Esq. Judith Elledge, Esq. Mary Sundt, Esq. March 3, 1992 Page 2 Further, within the next several weeks, we should know whether the entire case can be settled in accordance with the Magistrate's suggested settlement package. It is unfortunate that Goodrich has been such a "fly in the ointment" in this matter. Please call me if you have any questions. Best regards. Very truly yours, ' t' / . r '' - ; Sharon R. Burger SRB/jIf enclosure cc: Ms. Elizabeth Jacobson Ms. Jacqui A. Miraglia (File No. (File No. H105L-76-034969) #808 ERBY 225 33J) 5178i/ll privileged and "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 080800