Document jBZ4LOXB5yJKkm7ZJJyvVM2M5
October 6, 1995
MEMORANDUM OF SERVICES
Our services to the Chemstar Vinyl Chloride Panel in July and August 1995 included the following.
We reviewed materials circulated by Has Shah and spoke with him about the status of the ATSDR review of the reproductive and developmental toxicity study protocol.
On August 16, we met with Has Shah to discuss a problem that had arisen with ENSR in connection with the vinyl chloride epidemiology study update. We prepared a brief letter to ENSR suggesting that it promptly provide a sanitized version of the raw data in its possession and indicating that we would respond in more detail to a letter that Has had received from ENSR.
We reviewed the letter from ENSR, along with the contract with ENSR, and correspondence related to the contract. In addition, we reviewed the contract with AEI to conduct the update and assessed for AEI and CMA the implications of ENSR's delay in providing materials. We prepared a detailed response to the ENSR letter, and provided this draft to Has for review. We spoke with Has to go over the draft, and also spoke with Ken Mundt to obtain additional information concerning damages. We revised the draft letter and circulated to Has, Ken, and Jonathan Ramlow. On August 29, we discussed the letter with them on a conference call.
Following the call, we made further revisions to the letters.
PATTON BOGGS, L.L.P.
CMA 117896