Document xjn4OL1eeJzxj6kqOLeEQgzBQ

/ Ro b e r t L. Mu e l l e r Ro b e r t 'E. Da v l in Ric h a r d W. Gu n n in g De n n is S. O'Br ien L. Ro b e r t Mu e l l er Ke v in J. Da v l in LIVINGSTONE, MUELLER, GUNNING, O'BRIEN & DAVLIN, P.C. Attorneys at Law 620 Ea s t Ed w ar d s St r e e t Po s t Of f ic e Bo x 335 Sp r in c f ie l d , Il l in o is 62705 Te l e ph o n e (217) 525-1070 November 8, 1984 FORMERLY Liv in g s t o n e , Mu e l l e r , Dr a k e a n d Da v l in C. A. Liv in g s t o n e 1896-1982 Le s l ie V. Dr a k e tSr> REDACTED Mr. Steve Borgstrom Raymond Sheakley and Associates, Inc. 18 W 100 22nd Street Oakbrook Terrace, Illinois 60181 Dear Steve: In re: 81 OD 609 vs. Sherwin Williams I am. forwarding you a copy of the letter of John J. Larsen, Jr. indicating that he is entering his appearance as co-counsel with Ron Scharf. My inquiry for a toxicologist led me to a telephone contact with a Dr. Spikes who is with the Illinois Department of Public Health in Chicago (312-793-4766) . I talked to him for awhile on Wednesday, November 7 concerning the propensities of zinc oxide. His off the cuff impressions were that any compound could be toxic and that zinc could cause allergies. He did not classify it as an inert substance, but rather, ubiquitous. We talked late in the afternoon, and a few of the questions he asked I did not have the information at my fingertips. We agreed to talk again on Thursday morning. When I called him today, he had done seme research. Dr. Spikes identified several books and articles, the most recent of which is a 1980 publication of a Dr. Eleanor Berman on Toxic Metals and Their Analyses. Publisher was identified as Heyden. It is quite likely I will be able to find this at the SIU School of Medicine, here in Springfield. He also cited a publication of 1926 and a book on Industrial Toxicology published in 1974 by A. Hamilton and H. L. Hardy. When I run down these articles I might be able to get Dr. Spikes to write me a letter at least citing the articles, or in the alternative, we could have Dr. Van Ordstrand cite them. He does a pretty decent job of discussing the propensities of zinc oxide, and I am now looking at the third page of his letter to me of June 17, 1982. Another thought would be to ask Dr. Eleanor Berman to give us a specific written opinion. I was not impressed that Dr. Spikes was an expert on the toxicology of zinc oxide. With best regards, I am Very truly yours, h t- Robert L. Mueller RIM:ph N40290 0007-SWP-005801060 CONFIDENTIAL