Document rxmLgKRqn1rjNE49MagQzp6Ya

CHXCAOO LOS ANOSLES WASH3NOTON, D.C. Inna'S putgcr nttxbkb (212) 906-23M Sidley & Austin A PA*TN*inP WCLUDWO PKOPUSIONAL CORPORATIONS 875 ThzhD Avnnm New Yohx, New Yohx 10022 Telephone 212: 000-2000 Tkt.kx 97-ieee Facsimile 212: 906-2021 125* Ai^vii^aiy* 1866-1991 February 15, 1995 CONFIDENTIAL ATTORNEY WORK PRODUCT lKM7 LONDON SINGAPORE TOKYO VIA- FEDERAL EXPRESS Dr. Carlo H. Tamburro, M.D., M.P.H. Professor of Medicine, Pharmacology and Toxicology School of Medicine, 119A University of Louisville 319 Abraham Flexner St. Louisville, KY 40292 Re: Robert Eirven Dear Dr Tamburro: Enclosed are three volumes of medical records on Robert Eirven from: Humana Hospital, Clear Lake (Tabs 1 and 8) Gary B. Weiss, M.D. (Tabs 2 and 6) Beeler-Manske clinic (Tab 3) LaMarque Independent School District (Tab 4) Burton Hink, Jr., M.D. (Tab 5) Walgreen's Pharmacy (Tab 7) Miscellaneous Billing Statements (Tab 9) UCC Employee and Medical Records (Tab 10) Aetna Life & Casualty (Tab 11) Under separate cover, you will be receiving additional volumes of Mr. Eirven's medical records from Danforth Memorial Hospital, Mainland Center Hospital and Kalyanam Subra-Manyam, M.D. PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 073180 Sidley 8c Austin "k N ew York February 15, 1995 Page 2 As of today's date, we have yet to receive any of the slides or blocks prepared from Mr. Eirven's needle liver biopsy performed on or about February 4, 1992. We are still hopeful that this material will be found. X do wish to draw your attention to the records from Danforth Hospital. In September of 1983, Mr. Eirven was treated at Danforth Hospital. Among other things, he was evaluated for pancreatitis. Despite an inconclusive ultrasound and amylase levels within normal range, Mr. Eirven's treating physician stated as his final diagnosis "cluster headaches, vascular type; adult onset -diabetes mellitus, mild; essential hypertension out of control; and pancreatitis." I will be sending to you the industrial hygiene documentation regarding vinyl chloride from the Texas City plant under separate cover. 1 do also wish to confirm that this information can be retained by you pursuant to our understanding that the material will remain strictly confidential and that the data or records will not in any way be attributed to Robert Eirven or Union Carbide Corporation. I would appreciate it if you could confirm your billable hourly rate. I do also wish to confirm that on February 20th, I will be disclosing your name as a testifying expert in this matter. Thank you. Sincerely, Theodore J. Theophilos TJT/sr Enclosures cc: Robert Golden (w/out end.) Gregory Winfree, Esq., UCC Legal Dept, (w/out end.) PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 073181