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.4 LAW OFFICES OF <br />WILLIAM A. SCHUCKMAN <br />Ronald E. Baldwin July 27, 2000 <br />Page 2 <br />and (3) if the facility had no ventilation, no doors and no windows, then the concentration would be <br />approximately 4000 PPM. That concentration would be less than one tenth of the amount you claim <br />in your preprinted "Carbon Dioxide Facts" has been determined by the National Institute for <br />Occupational Safety and Health to be immediately dangerous to life and health. <br />Are you asserting that 4000 PPM constitutes an immediate danger to life and health? <br />I am sure you understand that effective regulation requires coherent, consistent and rational <br />statements from the regulating agency. We would appreciate your providing those at the earliest <br />possible time. <br />4. You cannot circumvent the Discovery Act by communicating directly with my client <br />or by conducting discovery under the pretext of some general "survey". Accordingly, with respect <br />to information relating to the subject matter of the pending lawsuit, it will be necessary for you to <br />proceed through Mr. Irey and in compliance with that Act. <br />With respect to matters which you feel are unrelated to the pending lawsuit we are, of course, <br />willing to cooperate with you once we have received the requested clarifications. <br />Yours very trul <br />WILLIAM A. SCHUCKMA <br />WAS/jaf/Encs. <br />CC: Mr. Michael Badway <br />Mr. David H. Irey <br />