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                                     Dr. Thomas J. Callender, M.D.  


                     913 S. College St.- Suite 102  *  Lafayette, LA 70503
                                (318) 233-6022, FAX (318) 269-0171


August 28, 1992


Strong & Associates, P.C.
Mr. Steven Harrell
901 E. Battlefield Rd.
Springfield, Missouri 65807


Re: Marie O'Hara Age: 33

Evaluated: January 1992

Dear Mr. Harrell:


Marie O'Hara was born on */*/**. Marie was a very active,
healthy person throughout her school age years (K-12). In
grades 1-6 she received A's and B's.


By 7th grade she was on the 3.5 honor roll, and in the 8th
grade continued with A's and B's. Also in 8th grade there
was a complimentary report sent to Marie's parents for her
outstanding work in science.


It also noted Marie to be a hard worker who well beyond the
call of duty and stated that she was always willing to help.
In 8th and 9th grades Marie was a lab assistant and received
comments by her teachers stating; excellent worker, perfect
scores and outstanding work.


At Lakenheath Junior High in 1973, she was accepted for
membership in the National Junior Honors Society of Secondary
Schools. Also in 1975, she was a member of Lackland National
Honor Society.


In 10th grade Marie continued to receive A's and B's and was a
member of the debate team, national honor society and a tutoring
service. In 11th grade she received A's and B's.


Her excellent grades continued in the 12th grade, during which
time she was taking two college level courses and on the staff of
the school newspaper. In 1977, at the end of her senior year in high
school Marie was listed as a member of the society of Distinguished
American High School Students.


In the Fall of 1977, Marie began attending Southwest Baptist
University in Bolivar, Missouri. She lived in the University dormitories
for approximately three years. She attended classes and was actively
present on the campus from September 1977 through Spring 1982.


During this period of time, Marie suffered periodic reoccurring
symptoms of irritability, dizziness, red ears, numbness of arm,
uncoordinated, nausea, muscle cramping and lethargy.


At the time, she did not know what was causing her failing health.
Marie's physical problems caused her great concern because she
did not understand the cause of her problems.


In the summer of 1983, Marie left the SBU campus. She began
a business endeavor called  "The Happy Helpers" to make money
for school bills and regain her strength. This job entailed writing
letters, grocery shopping, yardwork, etc., usually for elderly
                                               - 1 -

people unable to do for themselves. Her health gradually improved,
with only intermediate setbacks.


By the fall of 1988, Marie was ready to return to school. Her
health had improved, and she had earned enough money to pay off her
outstanding debts to SBU.


On September 26, 1988, within one month after returning to the
campus, Marie was exposed to pesticides. The pesticide was
being applied in the building while she was attending her class.


Her acute symptoms were severe headaches, numbness over
her entire body, swollen eyes, muscle spasms, upper and lower G.I.
disturbances, chest pain, and a burning respiratory tract.


She was diagnosed by Dr. A.S. Abdel Salam (Bolivar, Mo.) and
Dr. John Wolfe (Springfield, Mo.) as suffering from chemical
pneumonia
and chemical burns of the respiratory tract.


She now, for the first time, realized that pesticides had caused
her previous health problems while on the SBU campus. Her
current symptoms were acutely disabling and Marie was unable
to complete her school work that semester.


The following semester, Marie received assurances from SBU faculty
members that pesticides would no longer be applied on the campus
during business hours.


On January 30th, 1989, Marie was in the SBU Administration
building paying a parking ticket in order to register for two spring
courses. While in the administration building, Marie was again
exposed to pesticides during their application. The cumulative effect
of this exposure and the previous exposures have resulted in severe,
disabling neurological damage.


Since her exposure she has developed many symptoms including the
following: very irregular menses and fluctuations of weight.
For the first two years following her exposure, she reacted with
acute chest pain several times a day to cold air, exercise and strong
odors.


She has sties, irritations, double vision, visual disturbances,
twitching eyelides, dark circles under her eyes, and photosensitivity
of the eyes.


She has hearing loss, floating sensation, ear drainage and ear
pain. She also has seizure-like episodes lasting one to three minutes,
triggered by external stimulus.


She has nasal burning, bleeding, hypersalivation, excessive sweating,
gums bleeding, frequent sore throats, raw tongue, bad taste in her mouth,
swollen glands, hoarseness and difficulty swallowing due to burning in
her throat.


She has chest congestion, asthma, chronic bronchitis, and pleuritic
chest pain. These are worse with exposures to any airborne substances.


She has severe rashes over her entire body, dry brittle hair, ridges
on her nails, lips peeling, sores on her arms and bruises easily.

                                              -2-


She has painful, burning and difficult urination. She also has
muscle and joint pain, hands shake, muscle tremors and cramps,
extreme weakness and fatigue, tingling and numbness in her
extremities, old age like symptoms.


She has frequent vomiting with blood, diarrhea, abdominal
pain and cramps.


Since her exposure she has become hypersensitive to odors,
has frequent severe headaches, balance problems, impaired short
term memory, frequently her long term memory is impaired with
exposure, she has difficulty concentrating, confusion, disorientation,
irritability, and speech impairments.


She has problems with various stimuli causing seizures, such as
manipulation of 4th or 5th finger, intense concentration and certain
odors. She again became exhausted after 1988. She has sleep
disturbances, nightmares, and [several episodes of] hallucinations
[during the first week of the acute pesticide exposures of September
1988 and January 1989].

.

Several Tests were performed on Marie in January 1992 to help
determine the extent of her neurological dysfunction.


The following are her abnormal test results:

Abnormal: Contrast Sensitivity
Decreased low frequency contrast sensitivity, day vision and night
with central glare.

Abnormal: Pulmonary Function Test
Severe chest restriction.

Abnormal: California Verbal Learning Test,
Grossly atypical 1 - 5 standard deviations
Below norm - immediate & short delay were severely abnormal.

Abnormal: SPECT (Single Photon Emission Computerized Tomogram),
Decreased blood flow - Basal Ganglia Bilaterally

Abnormal: Quantitative sensory testing via Current Perception Threshold,
Severe Hyperesthetic condition - Left and right Median,
left and right Ulnar, left and right Trigeminal, left and right Peroneal.

Abnormal: Quantitative Romberg,
increased sway with eyes open, extreme sway with eyes closed.

Physical Examination: Poor drawing skills - difficulty
controlling pressure and had seizure-like episode secondary
to effort of drawing. Abnormal vibratory sense, with electrical
shock sensations. Gait abnormal ie dragged feet when walking
and poor balance on tandem walk. Alternating movements were
awkward.


These tests indicate nervous system dysfunction that by history
and pattern of injury is secondary to toxic inhalation of pesticides.

Her condition is analogous to the electrical system of a computer
that has had water poured over its circuit boards. Even after the
water has evaporated, the damage done to the

                                                   -3-


circuit is permanent. The damage done to Marie's neurocircuitry,
through inhalation of these chemicals via her olfactory system
or blood stream is also permanent. There is no residual of the
chemical, but the damage caused by its initial presence remains.


Now levels of chemicals not considered to be toxic, cause a
severe toxic reaction because damaged sensory processing or
movement related brain tissue is reacting inappropriately and
totally out of proportion to the stimulus.


In other words, her brain reacts to mild, common odors as
if it was detecting tear gas or rotten eggs and creating flu-like
symptoms with serious transient deterioration in mental and
emotional functioning, personality change, fatigue, memory
problems, etc..


These symptoms and intolerances make her quality of life
very unsatisfactory, and since such events are unavoidable,
she is constantly ill and in a state of perpetual disability.


It is my opinion that Marie O'Hara is permanently and
totally disabled due to a neurological illness that was
precipitated by her exposure to pesticides at her school.
She will need extensive medical and psychological support
in dealing with this terrible illness.


She may symptomatically respond to medication such as
dopamine specific anti-depressants, muscle relaxers and
anti-Parkinson's type medications.


Sincerely,


Thomas J. Callender, M.D.


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