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C. A. BROWN MAYO J. T H O M P S O N G E O R G E W. R E N A U D IN B R Y A N F. W I L L IA M S . J R . EDWARO J- PATTERSON. J R . G U S A- S C H IL L . J R . BEN L. REYNOLOS R IC H A R D D. D A V IS C HA RLES O. K E N N E D Y DECATUR J. H O L C O M B E O A V IO C . R E D F O R D K E N N E T H D- K U Y K E N D A L L TE D C . LIT T O N . ROBERT S. OE LANGE W ILLIA M M. J E N S E N JOHN R. PEARSON W. R O B IN S B R IC E CABLEGRAM "h O U PO R T" Ro yst o n, Rayz o r , Gook & Vic ke r y At t o r n e y s At La w S u it e 3710 One S hel l Pl aza H o u s t o n ,Te x a s 77002 A r e a C o d e 713 2 2 4 - 8 3 8 0 June 12, 1973 Dr. Robert A. Kehoe College of Medicine, Eden & Bethesda Avenues Kettering Laboratory Department of Environmental Health University of Cincinnati Cincinnati, Ohio 45219 M. L. C O O K OF COUNSEL GALVESTO N O F F IC E 2 0 5 COTTON EXCHANG E BLDG. Ga l v e s t o n , T e x a s 77550 AREA COOE 713 7 6 3 -1 6 2 3 CABLEGRAM "ROYSTON" MV EID - Our File 22,492 Dear Dr. Kehoe: We acknowledge receipt of your letter of June 7, 1973. Of course, the referred to remarks did give us some cause for concern; however, the writer (Kuykendall) was personally convinced that your remarks were a heart felt concern for the safety of the individuals from the hazards of tetraethyl lead rather than any irritability or irrationality on your part. We certainly want to thank you for your courtesy and cooperation in providing yourself for your deposition testimony, and we are of the opinion that your deposition testimony was most beneficial. It is certainly rare that we have the opportunity to confer with an individual with such experience as yourself and with such knowledge of this particular area. Generally, we deal with doctors who are basing their evaluation in part upon hearsay, study and research, rather than actual experience. We wish to relieve your mind of any concern with respect to the remarks made at the time of your deposition testimony. Of course, the plaintiff's attorney was glad to hear these remarks, but we feel that the Court will consider the fact that you do not have any personal knowledge of the events made the basis of such remarks. Moreover, the Court must certainly take notice of your outstanding qualifications and credentials in this area of tetraethyl lead poisoning. It was a great pleasure to meet with you and talk with you about this matter, and it is our hope that our next meeting will be on a topic of less serious nature. We certainly appreciate your cooperation and we would be most happy to reimburse you for any expenses associated in providing your cooperation or for any fee which you desire to charge in connection with your deposition. We certainly hope that the K 0006124 / Dr. Robert A. Kehoe - 2- June 12, 1973 deposition was not an imposition, and we apologize for the length of the deposition; however, in this type of matter it is very difficult, and almost impossible, to limit cross-examination by opposing counsel. Again, thank you. Yours very truly, KDK:wm RX 0006125