Document B50rwgEarJ2VjggGOXBYYNO7j

Nelson Mullins Nelson Mullins Riley & Scarborough LLP Attorneys and Counselors at Law Atlantic Station / 201 17th Street, NW / Suite 1700 / Atlanta, GA 30363 Tel: 404.322.6000 Fax: 404.322.6050 www.nelsonmull ins. com Lee Ann Anand Tel: 404.322.6595 leeann.anand@nelsonmullins.com April 25, 2011 Via Electronic Mail and U.S. Mail Robert C. Buck, Esq. Buck Law Firm 1050 Crown Pointe Parkway Suite 940 Atlanta, Georgia 30338 RE: Your letter of April 20, 2011 concerning these Georgia cases: Anna M. Evans v. Georgia-Pacific, LLC, et al. In the Superior Court of Clarke County, Georgia Civil Action File No. SU10CV1212-S Dorothy Blount v. Georgia-Pacific, LLC, et al. In the Superior Court of Dougherty County, Georgia Civil Action File No. 09CV3266-1 Rhonda Fields and Gary Fields v. Georgia-Pacific, LLC, et al. In the State Court of Cherokee County, Georgia Civil Action File No. 09-SC-0422 Clyde Stanley Phillips v. Georgia-Pacific, LLC In the State Court of Clayton County, Georgia Civil Action File No. 2009CV06410D Dear Rob: This letter will respond to your letter of April 20, 2011 complaining about Georgia-Pacific's alleged failure to comply with its obligation to produce documents in response to your supposed discovery requests in the Evans, Blount, Fields and Philips cases. With twelve office locations in the District of Columbia, Florida, Georgia, Massachusetts, North Carolina, South Carolina, and West Virginia Robert C. Buck, Esq. April 25, 2011 Page 2 First, I wanted to note that you have never served any document requests (or any form of written discovery requests) upon Georgia-Pacific in the Blount, Fields or Philips cases, so Georgia-Pacific has no current obligation to produce any documents in those matters. With respect to the Anna Evans case, Georgia-Pacific's responses to Plaintiffs Interrogatories and Requests for Production are due today and I am attaching those responses to this correspondence. As you will see, Georgia-Pacific is willing to produce any non-privileged documents that it can locate in its files relating to the studies you reference, and the Company will provide a log of materials protected by the attorney-client, work product or other applicable privileges. We are endeavoring to collect and log responsive materials now with a tentative goal of making a production in advance of your requested date of June 6, 2011. Please let me know if you have any questions. Sincerely, Attachments: Georgia-Pacific's Objections and Responses to Plaintiff Anna Evans' Interrogatories and Requests for Production of Documents to Georgia-Pacific. cc: Ian P. Cloud, Esq. (with attachments for the Anna Evans case) Jory D. Lange, Jr., Esq. (with attachments for the Anna Evans case) Christian H. Hartley, Esq. (w/o attachments) Gary M. DiMuzio, Esq. (w/o attachments) Keenan R.S. Nix, Esq. (w/o attachments)