Document zzGBM6Oj0zjODnLqG6m21DLXn

UNION CARBIDE CHEMICALS AND PLASTICS COMPANY INC. Law Departm nt 39 Old Ridg bury Road Danbury, CT 06817-0001 November 13, 1989 MEMORANDUM To: R. C. Wise K4-440 From: J. R. Downey, Esq. Re: Alice L. Warren v. The Dow Chemical Company, et al. I enclose a copy of the November 8, 1989 letter from Attorney John Tourtelotte, counsel to the plaintiff's estate. The information I enclose is self-explanatory. We are involved in a joint defense now with Dow Chemical. My suggested strategy is that we try to put together a r solution of this matter by way of a joint settlement proposal. I will discuss some of my thoughts with our outside counsel prior t finalizing a proposal. In the .meantime, I will attempt to contact Barbara Hensley to see if in fact there were sales of PVC and/or VCM to Monsanto, the plaintiff's employer. JRD/es Enclosure PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" ucc 082401