Document RJMQV4ENqGbXrJREkGj80gbBV

He w e s , Do u g l a s , Wh it in g & Qu in n ATTORNEYS AT LAW 103 EXCHANGE STREET P, O. BOX 7108 Po r t l a n d , Ma in e 0-4ii2-7i08 Ric h a r d D. He w e s Ma r t ic a S. Do u g l a s St e p h e n C. Wh it in g Th o ma s J. Qu in n Al is o n A. De n h a m De b o r a h Bu c c in a Ro g e r s El iz a b e t h Er n s t Ho o d Ric h a r d n . He w e s Ja me s E. Fo r t in Jo n a t h a n B. Hu n t in g t o n El iz a b e t h La n c a s t e r Pe o p l e s Sh e il a h R. Mc La u g h l in Er ic Lin d q u is t May 2, 1991 WORKERS' COMPENSATION Te l e p h o n e 207-77-4-1-486 Fa x 207-774-31-47 Ms. Mary Lee O'Brien Claims Adjuster Crawford & Company The Travelers Workers P.O. Box 5588 Manchester, NH 03108 Comp Unit REDACTED RE: File No.: vs. Sherwin-Williams Company 487CBBM83392T Dear Mary Lee: On April 30, 1991 I spoke with Peter Mills, Esquire about the future course of this case. A hearing will be held on May 13, 1991. We will need an independent medical examination by an allergist so that we can determine a diagnosis and a probable causal relationship between the chemical exposure and the condition. It will be important to learn if the employee suffers from pre-existing asthma that was simply aggravated temporarily by exposure to chemicals at work or if the asthmatic condition was caused by the exposure to chemicals at work and if it is still disabling the employee. If the work caused a temporary aggravation that has resolved, then the employee's condition has returned to the pre-injury level and we will be in a position to argue that the employee is entitled only to a closed-end period of compensation. On the other hand, if Mr. chronic asthma was caused by exposure to the chemicals at work, then the employee's disability (ongoing) will be causally related to the work injury and it will be compensable since it will not be deemed to have resolved. Second, we will have to take the deposition of Benjamin H. Hoffman, M.D. in order to obtain a favorable work restriction and I also hope to demonstrate that the doctor did not review enough test results to draw a connection between the employee's exposure to chemicals at work and the ongoing asthmatic condition. By copy of this letter, to Anthony Colangelo, I am asking that he send to me test results and data indicating the types of chemicals and agents that the employee was exposed to in the course of his employment at Sherwin-Wj.lliams and the levels of such exposure. N40242 0007-SWP-005802861 CONFIDENTIAL