Document NGMBLXr519yj3Nd0eQOKX3Bbb
ROBERT L. HOLUNGSHCAD
DIRECT DIAL NUMBER (SOI) 631-4817
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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