NEUROTOXICOLOGY      IMMUNOTOXICOLOGY
               GUNNAR HEUSER, M.D., Ph.D., F.A.C.P.    DIPL. MED. (McGILL)
                       NeuroMed and NeuroTox Associates   A Medical Group


October 13, 1992



Janet Hoffman, R.N.
Strong & Associates
901 E. Battlefield Road
Springfield, MO 65807



RE: Marie O'Hara


Dear Janet:

At the time of my visit with you and my examination of your client
I had occasion to review a number of medical records. These were
supplemented by records from Dr. Callender's office where she was
evaluated in early 1992. These were also carefully reviewed.


As you know, I also personally examined your client and reviewed
her whole situation with you and attorneys in your office.
At issue is the question whether exposure to pesticides (specifically
Diazinon) could be responsible for your client's present health
problems and total disability.


As you know, she still suffers from multi-system complaints and is
totally disabled with her problems which include severe allergies,
severe sensitivities to even small amounts of chemicals in the
environment, intermittent seizure-like events, upper respiratory
problems, breathing problems, and others.


Many of her health problems are documented in Dr. Worrell's records
and also in her letters. Dr. Worrell is a Board Certified allergist
and writes on 8-12-91 that Marie is a totally disabled and suffers
from a toxic reaction to chemical exposure, exhibiting severe
chemical sensitivity and other symptoms.


Since history and physical examination are not always convincing in
patients after chemical exposure, a number of objective laboratory
tests were obtained.


 ~~ CEDARS-SINAI MEDICAL TOWER 8631 W. THIRD STREET, STE 1025E LOS ANGELES, CA ~~

Page 2

Re: Marie O'Hara

A SPECT scan of the brain was abnormal and showed hypoperfusion.
This, in my opinion, is the effect of toxic chemical exposure on
brain function. It explains changes in behavior and also in
performance.


Evidence of auto-immunity was also found. Antiparietal cell
antibodies, anti brush border antibodies, antimicrosomal,
antibodies, antithyroglobulin antibodies, myelin autoantibodies,
and antismooth muscle antibodies are all elevated. These
findings are characteristic of patients who have been exposed
to toxic chemicals.


A number of tests have been performed and have ruled out diseases
such a porphyria, lupus, diabetes, hyperthyroidism, adrenal
insufficiency, heavy metal intoxication, liver disease, and others.


In view of the above, I have reached the conclusion that your client
indeed suffers from the consequences of chemical exposure and is
totally disabled as a result. Her activities are severely restricted
in view of severe allergies and also severe multiple chemical sensitivity.



Sincerely yours,


Gunnar Heuser, M.D.
Assistant Clinical Professor of
Medicine, U.C.L.A.

GH/lf

 ~~ CEDARS-SINAI MEDICAL TOWER 8631 W. THIRD STREET, STE 1025E LOS ANGELES, CA ~~

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

                         NEUROTOXICOLOGY      IMMUNOTOXICOLOGY
               GUNNAR HEUSER, M.D., Ph.D., F.A.C.P.    DIPL. MED. (McGILL)
                       NeuroMed and NeuroTox Associates   A Medical Group

October 20, 1992


Janet Hoffman, R.N.
Strong & Associates
901 E. Battlefield Rd.
Springfield, MO 65807-4800


Re: Maria O'Hara


Dear Ms. Hoffman:

I hope that you have received my report on your client.  This constitutes an
addendum to that report.


Ms. O'Hara's condition is such that it may well be life-long. Therefore,
he will be in need of a sheltered safe environment and daily help, potentially
for her lifetime.



Sincerely yours,

Gunnar Heuser, M.D.
GH/cms
...


 ~~ CEDARS-SINAI MEDICAL TOWER 8631 W. THIRD STREET, STE 1025E LOS ANGELES, CA ~~
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
                         NEUROTOXICOLOGY      IMMUNOTOXICOLOGY
               GUNNAR HEUSER, M.D., Ph.D., F.A.C.P.    DIPL. MED. (McGILL)
                       NeuroMed and NeuroTox Associates   A Medical Group



January 10, 1995


To Whom It May Concern:

Re: Marie O'Hara

This is to certify that I have personally seen and examined Ms. O'Hara.
I also had occasion to review her medical and related files.


Finally, I have kept in touch over the phone. Our last consultation
was in December 1994.


Based on the above, I have reached the conclusion that Ms. O'Hara
has suffered a chemical injury and that further exposure to even
small amounts of chemicals would be detrimental to her health.


Her chemical sensitivity is such that even small amounts of cologne,
perfume, cigarette smoke, solvents, etc. may produce significant
reactions including disorientation and impairment of consciousness.
This would potentially make her testimony at a deposition useless.


I recommend that the deposition proceed in a controlled (free from
chemicals) environment with either distance or a barrier placed
between attorneys/court reporter and the patient.


I believe that thirty minutes of deposition interspersed with up to
thirty minutes of rest would accomplish the goal of having Ms. O'Hara
being the best witness possible.


Gunnar Heuser, M.D.
GH/lf

 ~~ CEDARS-SINAI MEDICAL TOWER 8631 W. THIRD STREET, STE 1025E LOS ANGELES, CA ~~

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