VERIFICATION STATE OF CONNECTICUT) : SS. : COUNTY OF FAIRFIELD ) JOHN MACDONALD being duly sworn, deposes and says: Assistant Deponent is the Secretary of Union Carbide Corpora tion, a New York corporation which is a defendant in this action; deponent has read the foregoing answer and affirmative defenses and knows the contents thereof and the same is true to deponent's own knowledge except as to the matters alleged therein upon information and belief and those matters deponent believes to be true.

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ---------- ---------------------------------------------- ----------- --------- X NICOLINA SIRECI, as Executrix of the Estate of JOSEPH E.

DOW CHEMICAL U.S.A.

DOW CONFIDENTIAL AUTHORIZATION REQUEST COMPANY THE DOW CHEMICAL COMPANY ACQUISI TOR U CAPACITY, QUALITY, MIX j other title 1986 U.s.

F L UIU To: Sub j LAENV2::KEW LAENV2::KEW 27-OCT-1988 07:21 PROCESS CHANGE WITH LIMESTONE AND SLAG BED ADDITIONS PROCESS DESCRIPTION AFTER ADDITION OF LIMESTONE AND SLAG BEDS THE PROCESS WILL STAY ESSENTIALLY THE SAME WITH THE FOLLOWING EXCEPTIONS: 1.

CHEMICALS INTEROFFICE / LAKE CHARLES TO SHIPPING PERSONNEL DATE FEB 2, 1989 FRQM JIM LAFLEUR/SAFETY QAT SUBJECT SAFETY MEETING THERE WILL BE A SAFETY MEETING AT 7:00 AM ON MONDAY FEB 6TH AND MONDAY FEB 13TH TO REVIEW OUR SAFETY RECORD FOR 1988 AND GOALS FOR 1989.

i CARBIDE CORPORATION E lOAO.

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UNION CARBIDE CORPORATION SOLVENTS AND COATINGS MATERIALS DIVISION p. o. box 471. texas crrr.

.MANUFACTURING PRACTICES COMMITTEE: - ,,r-\ ^ ,, , , The Clarion 7401 North Scottsdale Road Scottsdale, Arizona .

File Group ==> OPERATING UNITS LAKE CHARLES ( 1983_C0RRESp0NDEtiCE /05,503 -105577'

UNION CARBIDE CORPORATION oldridgebubyroad, danbury. ct.06Bi7 LAW DEPARTMENT March 19, 1985 F.

CS ' ' UNION CARBIDE CHEMICALS AND PLASTICS COMPANY INC, Law Department 39 Old Rldgebury Road Danbury, CT 06817-0001 November 10, 1989 Cjks.

DOW CHEMICAL U.S.A.

DOW CHEMICAL U.S.A JUNE 22, 1982 LOUISIANA DIVISION P.