Document NGMBLXr519yj3Nd0eQOKX3Bbb

ROBERT L. HOLUNGSHCAD DIRECT DIAL NUMBER (SOI) 631-4817 irfl Pitney, Hardin, Kipp & Szuch 163 MADISON AVENUE P. O. BOX 1945 MORRISTOWN, NEW JERSEY 07960-1945 MORRISTOWN (201) 267*3333 NEW YORK (212) 926-0331 TELEX 6*42014 TELECOPIER (201) 267*3727 October 4, 1989 L>' v./ jrr NEWARK OFFICE 33 WASHINGTON STREET NEWARK, NEW JERSEY 07102 (SOI) 623*1900 John Downey# Esq. Union Carbide Corporation Law Department E3-285 39 Old Ridgebury Road Danbury, CT 06817-0001 "cONFfoENrSfMAND Subject topt>n?JERIAL OR0ER.OECT'Ve Re: Peterson v. Union Carbide Corporation Dear John: Enclosed please find copies of the following expert reports that were served on us yesterday on behalf of the plaintiffs: / 1. Report of Henry Velez, M.D., dated ^ August 15/ 1989. y'/2. Preliminary Report of Epstein, M.D., 13, 1989. dated Samuel S. September As you know from our recent conversations, I have submitted material from this case to Dr. Ted Loomis, who will serve as one of our expert witnesses. Dr. Loomis has previously served as an expert on a Union Carbide matter and is presently assisting me as an expert on two major cases for Allied. As you can see from the enclosed C.V.'s, he is both a medicc. doctor and toxicologist. I am today sending the reports of Drs. Velez and Epstein to Dr. Loomis for consideration in the preparation of his expert report. Please call me as soon as you have to review the enclosed reports. a chance Sincerely, OCT 0 1989 3 RLH:lh Enclosures ROBERT L. HOLLINGSHEAD i cc: Mr. R. C. Wise (w/encs.) Mr. Nick Wheeler, Jr. (w/encs.) UCC 088523