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

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 form 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 porphyrria, 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

*********************************************************
 

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

NEUROTOXICOLOGY                      IMMUNOTOXICOLOGY

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, she 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

---

 

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

NEUROTOXICOLOGY                      IMMUNOTOXICOLOGY

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