Document zQb8Y600NwMnxZE4RYKNMpEw0

PFR-22-2003 11:53 ft*TT f> i4BTT66 Line |"5|3) 5*4 5161 Weil, Gotshal & Manges llp 700 Louisiana >gi ie <600 HOUSTON, TEXAS '7052.2704 ('13) S46.SOOU FAX; (7131 224.9*11 April 17,2003 F.02 // BA6LAS N6NLO PARK in iicon MIAMI NEW YORK Wi C l ll NO TO N . &. BRUSSELS Budapest LONDOH r KA j Jb WARSAW gCgrti/8erfMaa.XK* TOM 2226 QMS 0660 2979 Mr. Eugene Egdorf The Lanier Law Finn, PC 6810 FM 1960 West Houston, Texas 77069 Re; No. 197S5-BH02, KeUy*Moore Paint Company, Inc. v. Dow Chemical Company, et aL, In the 23rd Judicial District Court. Brazoria County, Texas Dear Gene: We are in receipt of >oui responses lo The Dow Chemical Company's Second Set of Requests for Production of Documents. In Kelly-Moore's responses to Requests for Production Nos. 5 through 14, you refer to a number of documents that Dr. David Egilman possesses and claim that `Ttjhese documents are available for review on Dr. Egilman*s website at www.eeilman.com." Many of the documents referenced in Dr. Egilman's Web site are not available. A link in Dr. Egihnan's opening webpage leads Lo the "Duw Lost Document* Program" (*#** Attachment A), which contain* six additional links, purportedly links to additional documents referenced in your responses to Dow's Second Set of Requests for Production of Documents. The first link, entitled '`Influence over ACGEH," states that this page cannot be found. Similarly, the links entitled "Dow Hidden Document Program," "DOW Nazi Consultant Otto Ambrose," `"Found Documents," and "Tons of Dow Documents" (Attachments B-F, respectively) are also identified as pages (hat cannot be found. Similarly, the link alleging that Dow "did intentionally destroy or hide some tc avoid liability." also leads to a page that carnnt be found. Also on the initial webpage for Dr. Egilman's site, is a link entitled ' Document Center," This page states that it is "restricted access," and chat ` No one may access our restricted section without first requesting a user name and password from HOli'263W0] US90C1IDCC42253 .COW > PFR-22-2003 11:53 WEiL, GOTSHAia Manoes LLP Mr. Bugetie Egdorf April 17, 2003 Page 2 F.03 Dr. EgUtnan" Tber* are other links in Dr. Egilman's Web site that purport to lead to Dow material, but require a passport for access (see Attachment G). As we do not wish to contact your expert directly, we request that we be given a mtr name and password to access this section of Dr. Egilman's Web site. If you have any questions regarding the requests herein, pleaae do not hesitate to contact me. Very truly yows, $DL:mtc Enclosures \5cdtt D. Lassotter (ioi i6<mioivS:ceiLDOC'4Ji5}.cM4 2