Document gED4gBGpdg6wnaKengjKDYB0q

:[VU EBB WJf. U! Pitney, Hardin, Kipp & Szuch U R-L WHITE (MAIL. TO) P. O. BOX 1945 MORRISTOWN. NEW JERSEY 07962-J945 [DELIVERY TO! ROBERT L. HOLUNGSHEAD 200 CAMPUS DRIVE DIRECT DIAL NUMBER (200 ses-eo'7 FLQRHAM PARK. NEW JERSEY 07932-0950 FLORHAM PARK (201) 966-6300 NEW YORK (212) 926-0331 TELEX 6420U FACSIMILE (201/ 966-1350 NEWARK OFFICE 33 WASHINGTON STREET NEWARK. NEW JERSEY 07102 (200 G23-I9BO April 9, 1993 BY UPS OVERNIGHT MAIL Tracking No: 0203 9489 268 Gregory A. Lalim, Esq. Union Carbide Corporation Law Department E3-285 39 Old Ridgebury Road Danbury, CT 06817-0001 Re: Colby v. Union Carbide Corporation Dear Greg: Pursuant to our discussion today, I am enclosing a copy of a memo, dated March 30, 1993, from my associate, Kathryn Decker, regarding oncologists who might serve as expert witnesses on Union Carbide's behalf in this matter. C.V.'s for some of these experts are also enclosed. As soon as we receive C.V.'s for the others, we will forward them to you. Also please note that we are compiling a list of toxicologists who may serve as experts and will forward that list as soon as it is completed, as well. As we agreed, Kathryn and I will call you on Monday to discuss these experts in more detail. Sincerely, RLH:pc Enclosures ROBERT L. HOLLINGSHEAD PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 075831 PITNEY, HARDIN, KIPP & SZUCH INTRA-OFFICE MEMORANDUM TO. R. L. HOLLINGSHEAD oath March 30, 1993 moM. K. M DECKER COW TO. mmtcr: COLBY V. UNION CARBIDE CORPORATION Set forth below is a preliminary list of medical defense experts for your consideration in the above referenced case: I. INTERHIST/ONCOLOGIST A. Michael Scoppetullo M.D. (specializing in Oncology) 36 Newark Avenue, Suite 304 Belleville, NJ 07109 (201) 751-8880 Dr. Scoppetullo has testified for me in the past in medical malpractice actions. He has testified on behalf of plaintiff and defendant. I spoke with him briefly on the telephone the other day to see if he would be interested in reviewing this case, after discussing it in very general terms. I am obtaining a copy of his c.v. B. Frederick B. Cohen M.D. (specializing in Internal Medicine and Medical Oncology) Beth Israel Medical Center 201 Lyons Avenue Newark, NJ 07112 (201) 926-7230 Dr. Cohen has testified on behalf of the defense for the most part, but recently began to review cases for plaintiffs. PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" ucc 075832 C. Arnold Rubin, M.D. (specializing in Oncology) 174 Union Strdot Ridgewood, NJ 07450 (201) 444-2528 '-r Dr. Rubin has testified primarily for the defense but .recently has reviewed cases for plaintiffs. He is also the Chairman of the Oncology/Henatology Department at St. Joseph's Hospital in Paterson. D. Michael J. Wissenblatt M.D. (Medical Oncologist/Hematologist) Central Jersey Oncological Center 205 Easton Avenue New Brunswick, NJ 08901 (908-826-9570) Dr. Nissenblatt has been utilized as an expert primarily for the defense. Although I have never retained him personally, he has been my adversary's witness on more than one occasion. He is mediocre. However, his location in New Brunswick may be advantageous with a Middlesex County jury. He also holds several positions on the staff of Robert Wood Johnson Hospital and St. Peter's Medical Center, both hospitals located in Middlesex County. E. Charles A. Leff M.D. Lawrence S. Boons M.D*. (specializing in Internal Medicine/Oncology) 1314 Park Avenue Plainfield, NJ 07060 (908) 754-0400 This group was recommended by a neurosurgeon who has served as my expert in the past. This group has privileges at Muhlenberg Hospital, Somerset Medical Center and St. Peter's Medical Center. F. Louis Aledort M.D. (Oncologist) c/o Mt. Sinai Hospital New York, NY This physician was considered for use as an expert in asbestos litigation. He also has been used as a defense witness in medical malpractice actions. His credentials are very impressive. Attached is a copy -2- PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 075833 of his C.v. for your review G. Peter Levine Qeller, M.D. (Surgeon) Columbia Presbyterian Hospital Hev York, NY Attached is a copy of his C.v. H. David 1. Befeler, M.D. (Surgeon) 709 Springfield Avenue Summit, NJ (908) 277--3232 I am obtaining a copy of his C.V. PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" 3- UCC 075834 UNION CARBIDE CORPORATION 39 Old Ridgebury Road Danbury, CT06817-0001 Law Department Gregory A. Lalfm (E3-285) (Telephone: 203-794-5196) MEMORANDUM To: Betty-Lynn White, Esq. From: Gregory A. Lalim, Esq. Re: Colby pi*i March 22,1993 c^A Per your suggestion, we have checked the files of prior vinyi chloride cases, but have been unable to locate any expert witnesses. Our outside counsel has informed me that experts he has previously utilized are retired (or worse). I also touched base with J. O'Gara, but his cases never reached that stage. GAL/es PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 075835 39 Old Rldgebury Road Danbury, CT 06817-0001 Law Department Gregory A. Lallm (E3PZ85) (Telephone: 203-794-5196) MEMORANDUM To: Betty-Lynn White, Esq. From: Gregory A. Lalim, Esq. Re: Colbv Plaintiff in the above-referenced action, now deceased, alleges that he contracted liver cancer due to exposure to, inter alia, vinyl chloride while employed at the Amboy OTD Terminal from 1960-67. I was wondering if you had any experience with an oncologist and/or toxicologist who might be appropriate witnesses in this matter, or perhaps c direct me to someone who has. GAL/es PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" :: s il \7 3 tcc UCC 075836