Document J13Ez9EQypn6ywkgbbR63jn2

KATHRYN M. DECKER DIRECT DIAL NUMBER <201) 900-8092 Pitney, Hardin, Kipp & Szuch (MAIL TO) P.O. BOX 1945 MORRISTOWN, NEW JERSEY 07962-iaAS (DELIVERY TO) 200 CAMPUS DRIVE FLORHAM PARK. NEW JERSEY 07932-0950 4 JD TELEX 6-4SOM sifVCfc soi) aee-isso SEP 2 01993 FLORHAM PARK (201) 966-6300 NEW YORK (212) 926-0331 G.D. WINFREE September 16, 1993 Gregory D. Winfree, Esq. Litigation Counsel Union Carbide Corporation Law Department, E3-285 39 Old Ridgebury Road Danbury, CT 06817-0001 Re: Colby v. Union Carbide Corporation Docket No. L-1979-91 Dear Greg: Enclosed please find the curriculum vitae of Patrick A. Gaughan, Ph.D., the economic expert we have retained on behalf of Union Carbide in this matter. Please let me know if I can provide you with any additional information. Sincerely yours, M bJl KATHRYN M. DECKER Enclosure cc: Robert L. Holliingshead, Esq., (w/o end.) privileged and s?jrmp!'tNTIAL MATER|AL SUBJECT TO PROTECTIVE ORDER" UCC 075707 * 09/13/1993 12:30 2016353848 ECONOMATRIX fT "APCH PAGE 02 Patrick A. Gaughan Biographical Data CURRENT POSITIONS I PREVIOUS POSITIONS! PREVIOUS FACULTY POSITIONS! Prilidinti Ccongaatrlx Baaaarch Aaaoclatas Inc. Economatrix Raaaarch Asaociatas Inc. ia a consulting firm which conducts economic and financial analyses for litigation support and for pura rasaarch. These sarvicas includa tha financial evaluation of firm's involved in mergers or acquisitions or for tha purpose of litigation. The firm also develops analyses and provides expert witness testimony for litigation support in corporate as well as personal injury, wrongful death, wrongful dismissal and other types of litigation. Research studies center on the estimation of damages in litigation economics, the role of institutional investors in capital markets and mergers and acquisitions. Associate Professor - Tenured College at Buslnees; graduate LSYRl Palrlilgh BiuKinggp University Teaching Mergers a Acquisitions, Financial Analysis, Corporate Financial Policy. Have taught Securities and Investments, Money a Banking, MicroeconomicsL and Macroeconomics. Supervise Graduate Research in Economics and Finance Chairman of College of Business committee on Curriculum Elected Member of University Senate Ssongalitt hXZL commUetlone , Developed econometric models and forecasts for AT&T services which were used for pricing and lon^ term planning by various divisions of the firm. Analyzed and developed forecasting methodologies for firm! university o Missouri Baruch College Fordham University Graduate School qZ Management Marwllle college Hunter College St. Louis, MO. New York city New York city St. Louis, MO. New York City UCC 075708 09/13/1993 12:30 2016353848 ECONOMATRIX F 'ARCH PAGE 03 xpgcATiom PfttPii lX MnlVfgeitY SI Ufig York Graduate Center University flf Chicago Fields of specializations Corporate Finance Applied Microeconomics Econometrics HiPflILj fiAo. City University fit HIM Xark Graduate Csntey Concentration: Applied Microeconomics Macroeconomics Econometrics FUBLXCATXOMSI Msrosrs and Acquisitions Harper Collins Publishers $ March, 1991 one of the first college textbooks in the field of mergers and acquisitions. "Measuring Damages Related to Reduced System Functionality", Journal fit LftSfil Economics^ (expected in iJuly 1993) co-authors: Paul Lerman and Donald Manley "Minimization of Taxabla Income and Corporate Lost Profits Litigation" Journal fit Forensic Economics. Winter, 1990 MA Quantitative Model of Securitise Trading Activity" in MattHKlB and laautt in Litigation Economics (accepted & forthcoming) "Economic and Financial Issues for the Estimation of Damages in Commercial Litigation" I in Methods and XfifiUfifi in Litigation Economics (accepted & forthcoming) "The Use of Statistical Analysis in Employment Litigation", in MfthOds and IfifiUlfi lQ liitica:iian Economics (accepted ft forthcoming) "Current Trande in the Financing of Mergers, Acquisitions and Leveraged Buyouts in Readings Jji Maraara find Acaulaltiona (accepted It forthcoming) UCC 075709 09/13/1993 12:30 2018353848 ECGNOMATRIX F "ARCH PAGE 04 ''Pension Fund Turnover and Trading Patterns] A Pilot Study", Columbia Unlvaraltv School ofLaw, Center Cor LftU end Economic Studies Monograph. January, 1991 , "Institutional Investors and Their Role In Securities Markets'1 Columbia Unlvaraltv School of Law! Center For IdUf And Economics Monograph, Fall, 1989 This study was used citsd and used as a basis for ths report prepared by the ju A* Senate commltte# an Banking, Homing end umn Affairs: subconeittes sn securities, entitled, "institutional Investors and Corporate America: Conflicts and Resolutions, October 3, 1989 "Hedonic Damages in Wrongful Death litigationR HflU Jsrsav Journalf November, 1988 "The Estimation of Hedonic Damages in Wrongful Death Litigation: The Evidence From Economic Research" in The Estimation at Damages by Gerald Martin, Jamesvay Publishing company, 1989 "Financial Deregulation Banking Mergers and t}he Impact on Regional Businesses" Proceedings at hft Pacific Northwest Regional Economic Conference Sprilig 1988 "Published News and Stock Prices" in Investment Decisions December, 1986 'An Analysis of ths Impact of Published News on stock Prices and Trading Volume", University Mlerc films, 1986 "An Analysis of ths Effscts of ths 1980 Recession upon the Electric Utilities, Mining And Petrolei Industries". in Recession In The United Stah ESBnPBi.fi EfftCtl and EfilifiX Iirolicoticna. Library of Congress, July 1980 UCC 075710 09/13/1993 12:30 2016353848 ECONOMATRIX F?-----ARCH PAGE 05 BOOKS UXDBB COHTRACTl PUBLISHED ABSTRACTS corporats rinancs o Bankruptcy Graduate level textbook Basil Blackwell Publishing Company, oxford, United Kingdom (expactad 1994) Methods and Ififiuaa in Litigation Economic*, (axpactad 1993) JAI Prass Series in Economics and Financa aditad by Patrick Gaughan and Robert Thorton Readings in Mergers and Acquisition* Basil Blackwell Publishing Company, (expectnd 1993) Oxford, United Kingdom M Hedonic Damages in Personal Injury and Wrongful Death Caeee" Journal Forensic Economics. August, 1990 Referred journal. SSHIKAR PAPSRflt "The Use of Statistical Analysis in Employment Litigation", Unlvorsitv MlSBQUrl LMM UatlQQl* Seminar materials for Forensio Economies Conference UCC 075711 09/13/1993 12:30 2018353848 ECONQMATRIX Rf *CH PAGE 06 FASflEMTXTZOllS s "The impact of Public Nava on Securitiaa Markets and th* Implication* for corporate Policies", seminar conducted for the Commodity fgtUTflfl 'Trading Conmiiilon "Financial Deregulation, Banking Margara and itha Economic impact on Regional Businesses" Pacific NorthWMt Raaianal BcanOBiC Confaranc* ! "Economic and Financial Issues in Corporate Litigation" USU Jersey fiat Association Confaranoa **Tha Economic Outlook and th* Impact on Investment Decisions" National credit Union Conference sponsored by AT&T "The Economic Outlook and the Impact on the Commercial Construction Industry" Society Ear Marketing! Professional Services "The Use of Exposure Measuring Techniguee ini Litigation Economics" National Association Forensic feconomists Eastern Economics Aeeoclation Meeting# | "Economic Loss Analysis in wrongful Dismissal Litigation: A Methodology" American Economics Xffflocifltlfln Annual Meetings "Hedonio Losses in wrongful Death Litigation Economic Analysis" Eastern Economics AfQglttlfln MHtlMB An "Minimization of Taxable income and Corporatje Lost Profits Litigation" Western Economics Association Meetings "A Theoretical Model For The Use of Statistical Analysis in Employment Litigation" American Economics Association A&DU&1 Meetlnjae "An Analysis of the Role of Pre-Judgement Interest And The Time To Trial: An Empirical study" j Eastern Economics Aeeoclation Annual HftBtlfWjS "Economic and Financial lasues in Lost Profits Litigation" (accepted but did not praeant) Western Economics Association Annual Meetings U<FC 075712 09/13/1993 12:30 2016353848 ECONOMATRIX RF RCH PAGE 07 research STUDIES Conducted economic and financial analysis of the the leveraged buyout of ths Revco drug store chain which was one of ths first major LBO's to default. This research was published by the II*. a*. House of RtprSSflntatlYfg Committee fin EnsrqY and Comnlerca in "Leveraged Buyouts and th* Efit fi Soldi 12Ju Update" "The Growth of Institutional Investors - Updated Data: 1981 - 1988" 1 institutional xnYtstor Proltot Columbia University LflM School Center LAN ADd BffPnoalffl 8tudles^ January, 12, 1990 UHXVEMIT* PRESENTATIONS! "The Impact of Public News on Securities Maxfkets and the Implications for Corporate Policies11, seminar conducted at Southeast Missouri Stats University. Economics Department Seminar, 1985. "An Analysis of ths Volatility of the Bond * arket", seminar conducted at Falrlelch Dickinson Si lYsraltYi Economics and Plnancs Department Seminar, 1 988. "Pension Fund Turnover and Institutional In\aster Trading patterns", seminar conducted at Pace University. Finance Department Seminar, 1990. "Utilising Original Caee Studies in Corporet Finance Courses" seminar conducted at Fain Sigh Dickinson University. Economics end Finance Department Seminar, 1991 BOOK UVZIVft ZhB Economies Monsv, Banking Allfl Financial Marksts. by Frsderic Mishkin, Glenview, 111, 2nd Edition, 1989, Reviewed for publisher Scott Foreseen * Co, Investments by Ben Branch, Chicago, 2nd Edition, 1989, Reviewed for publisher Longman Financial Services ijcC 075713 09/13/1993 12:30 2016353848 ECONOMATRIX P' "ARCH PAGE 08 COWTERXlfCB CfiAXRMASSBZFSI Chalrad session on Litigation Economic*, National Association of Forsnslc Economists Eaatarn Economic. AltQCjLfltlon Annuli Mlltlnfet Baltimore, 1989 Chairsd Saaaion on Litigation Economics, National Association of Forsnslc Economists Eastarn Economics Association Annual Mastinfrs Cincinnati, 1990 Chairsd Sassion on Litigation Economics, National Association of Forsnslc Boonomists Eaatsrn Economics ASSPSiltign Annual MSMtlnt Pittsburgh, 1991 Chairsd Sassion on Litigation Bconomics, National Association of Foransic Economists Eastsrn Bgpnomlgfl Association Annuli Maatlnga Nav York, 1992 Chairsd Sssslon on Litigation Economics, National Association of Foransio Economists Saittm Eoonomica Association Annual Maafclncts Washington D.C., March, 1993 JOURS*!. Rimni Rafarss for tha Journal Eorsnalc Economic s Rsfsrss for tha Journal a Lagal Economics JOURNAL EDITOR8RIP8I Sslsctad to sarva as tha Editor of tha "Spaclial Issue on Commercial Damages" of the Journal |of Forsnslc Economics. Summer, 1993 COSTZSUZMO SDUCATIOW WORKSHOPS "Ths Methodology of Valuing a Busineae" continuing Education Workshop for Fh.D. Economists Wrttrn Bconomlca Aaaoclatlon Annual Hiftlngja San Francisco, 1992 Served as workshop chair and faculty member. UfCC 075714 ...... i. 09/13/1993 12:30 2016353848 ECONCMATRIX RF" 09 BBSBASICS ojuunai Columbia Dwlvttiltv school of Law cntar for Lav and Economics. 1988 Grant to research tha iiza and role of inst .tutional investors in capital markets. Columbia nnlvinitv Behor.1 of T^w j cmtar for Law and Economics. 1990 1 Grant to conduct a pilot atudy which would develop a quantitative modal and data baaa to measure;the trading patterna of larger panaion funds. | Columbia Pnlvaraitv School of Lav i cantar foriaw and Economics, 1991 1 Grant to update prior research on tha size and role of institutional investors in capital markets.! working mnsi "Tha Volatility of tha Bond Market" ] DISTINCTIONS: "Statistical Evidence and Employment Litigation" Biographical Data Including Inx who^ Who xi The East Who1 a Khs Id Finance and industry PROFESSIONAL Vioa President and Member of Board of; Directors affiliations> National Association of Forensic Economists National Association of Business Economists American Economic Association American Finance Association Financial Management Association Eastern Economics Association Western Finance Association I UCC 075715 03/13/1993 12: 30 2016353848 ECONCf^TRIX RF" ,,RCH PAGE 10 "Economic and Financial Zaaues in Measuring Commercial Damages", Eatirn EPWMUSB Association Annual Mastlnof Pittsburgh, 1991 1 "1 "Economic and Financial Analysis in Leveraged Buyout Fraudulant Conveyance Litigation" | ABSrlgftn Economics Aaaociation Annual Meetings New Orleans, 1992 ;i "Measuring Damages Resulting From Reduced Functionality of Systems" EftSttm EgPPPmigfl ASSQCiatjgn Annual Meetings! New York, 1992 " "Measuring Damages in Commercial Litigation" lattttxghttnqt Carriers Aqgoglatign San Diego, 1992 "Meaauring Damages Rsaultlng From Reduced Functionality of Systems" Halfm Economics Aaaflslfltlen Annual Maatlnaa San Francisco, 1992 "Dus Dlligencs Process for Highly Leveraged Financial Transactions" Biittra BggpmlfiB association Annual Hsstings Washington D.C., 1993 7 "The Lew a Economics of Telecommunications Tol11 Fraud" i fiaatsrn Bconsniffs Association Annual Msetings Washington D.c., 1993 ! "laossss in Commercial Litigation" Western Economics AtflPglfttUn Annual Halting* Lake Tahoe, 1993 {paper presented by co-authors) \icC 075716