**August 30, 1996**

**Ms. Elaine Demske**
Claim Account Executive
**ZURICH-AMERICAN INSURANCE COMPANY**
One Liberty Plaza - 52nd Floor
New York, New York 10006

**INTERNATIONAL BUSINESS MACHINES CORPORATION**
**RUFFING, ET AL VS. UNION CARBIDE CORPORATION, ET AL**

Dear Ms. Demske:

Enclosed is a copy of plaintiff's summons & complaint which has been served upon International Business Machines Corporation in connection with the captioned matter.

The complaint alleges that plaintiffs other than the infant plaintiffs were harmed as a result of prolonged contact and exposure to harmful chemicals while employed in certain buildings at IBM plants where semiconductor products were being manufactured and assembled for use in computers. In the case of infant plaintiffs, it is alleged that their parents were in contact with and exposed to harmful chemicals prior to their birth while employed in certain buildings at IBM plants.

The complaint does not specifically state the relationship between plaintiffs and International Business Machines Corporation and consequently Liberty Mutual Insurance Company who is the Employers Liability carrier for International Business Machines Corporation during the alleged exposure period of 1964 to 1996 has been notified of this matter. American International Group who provides General Liability coverage for International Business Machines Corporation from 1/1/95 to the present has also been notified of this litigation. Enclosed are copies of my notifications to these carriers.

International Business Machines Corporation has retained the Jones, Day firm to protect their interests. The following attorneys from Jones, Day are leading the defense of this case.

IBM-ZRIND 64180