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o LAW OFFICES OF <br />! <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 />WAS/jaf/Encs. <br />CC: Mr. Michael Badway <br />,Mr. David H. irey <br />Yours very true 3 " <br />WILLIAM A. SCHUCKMAN <br />L66L aunt 008E W'Od Sd <br />.ia <br />oC <br />(L c <br />a� 'M <br />m <br />c <br />a <br />° <br />U <br />N <br />S <br />O <br />F <br />o <br />QU <br />d N <br />A (D C N d <br />i- <br />in <br />3 N <br />W <br />cpCr <br />V <br />i .> <br />C N <br />R a► <br />OCU z in <br />L <br />I <br />o <br />m > <br />N <br />m <br />a <br />Z c <br />mo <br />_yam <br />W� <br />¢ <br />WY <br />`m m ,c <br />m y c r <br />c 1p <br />F <br />M <br />ina a U <br />o¢ <br />p <br />as a <br />L66L aunt 008E W'Od Sd <br />