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 7/13/59.  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 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 Happy Helpers to make money for school bills and regain her strength.  This job entailed writing letters, grocery shopping, yardwork, etc., usually for elderly  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 Administra- tion 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.

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 concentratation and certain odors.  She  again became exhausted after 1988.  She has sleep disturbances,  nightmares, and hallucinations.

     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 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 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.
                                   (Original copy signed by Dr. Callender)