Document zoVrMDN5G7aG9erZDnoRDRQma

1 PHILBIN & ASSOCIATES 95 State Street 2 Springfield, MA 01103 (413) 733-4078 3 , 199 1 4 5 ROBERT P. POWERS, ESQUIRE Me 1ick & Porter 6 One Joy Street Boston, Massachusetts 02108 7 RE: WARREN ET AL VS. DOW CHEMICAL ET AL 8 Dear Mr. Powers: 9 Attached is the Signature Page-Errata Sheet for 10 the deposition of ROBERT BOURGET taken on February 25, 1991 in the above-captioned case. 11 Please note that according to the Rules of Civil 1 2 Procedure, the deponent has thirty (30) days in which to make these corrections on the transcript. 13 When the deponent has signed and noted his/her 14 corrections on the Signature Page-Errata Sheet, indicating the page number, line number, and the 1 5 desired corrections, please return the original to Mr. Minoff, forwarding copies to all counsel. 16 Thank you for your cooperation. 17 Very truly yours, 18 19 Joanne Coy1e Certified Shorthand Reporter 20 2 1 cc: All counse1 enc . 22 23 090666 COMPUTERIZED TRANSCRIPTION PHILBIN & ASSOCIATES J OC 9 (R*v, 10/82) DEPOSITION SUBPOENA J5>taies district (Court DISTRICT f./[assac|luse|:ts ALICE L. WARREN, ADMINISTRATRIX OF THE ESTATE OF JOHN H. WARREN, DECEASED V. THE DOW CHEMICAL COMPANY, et. al. DOCKET NO. 89-30201-F TYPE OF CASE G3 CIVIL CRIMINAL SUBPOENA FOR H PERSON XXDOCUMENT(S) or OBJECT(S) TO:Robert Bourgot, c/o Monsanto Chemical Company 730 Worcester Street Indian Orchard, MA 01151 YOU ARE HEREBY COMMANDED to appear at the place, date, and time specified below to testify at the taking of a deposition in the above-entitled case. % PLACE Robinson Donovan Madden & Barry, P.C. 1500 Main Street, Suite 1400 Spr irigf i e Id, MA 01115 DATE AND Tlk/ft ^ February-2'6, 1991 at 1:00pm YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s):1 PLEASE SEE! ATTACHED EXHIBIT "A" Please see additional information on reverse Any subpoenaed organization not a party to this suit is hereby admonished pursuant to Rule 30 (b) (6), Federal Rules of Civil Procedure, to file a designation with the court specifying one or more officers, directors, or managing agents, or other persons who consent to testify on its behalf, and shall set forth, for each person designated, the matters on which he will testify or produce documents or things. The persons so designated shall testify as to matters known or reasonably available to the organization. U.S. MAGISTRATE (2) OR CLERK OF COURT DATE EGBERT J. smith; m (BY) DEPUTY CLERK j Hi0| 1- \ This subpoena is is^ | 0 Plaintiff d upon application of the: H Defendant U.S. Attorney ATTORNEY'S NAME AND ADDRESS Keith A. Minoff, Esq. Robinson Donovan Madden & Barry, P.C. 1500 Main Street, Suite 1400 Springfield, MA 01115 (413) 732-2301 (1) If not applicable, enter "none." (2) A subpoena shall be issued by a magistrate in a proceeding before him, but need not be under the seal of the court. (Rule 17(a),^ederM j Criminal Procedure.) *./ V U O t EXHIBIT A Any and all documents in your possession, custody or control referring to, relating to, or evidencing any vinyl chloride monomer and other vinyl chloride delivered, shipped, supplied, sold or furnished to Monsanto's Indian Orchard plant in Springfield, MA from 1947 through 1974, including but not limited to contracts, purchase orders, invoices, receipts, bills of lading, material safety data sheets, logs, railroad documents, laboratory logs, data books, material and identification tags, tank card documents, correspondence, memoranda, etc. Any and all documents setting forth or referring to Monsanto's policies and procedures for the retention and destruction of any of the documents requested in Item No. 1 from 1974 to the present.