http://downey.kaiserpapers.info/injured/index.html

Theatrical Stage Employees that developed long term, debilitating illnesses while working at Downey Studios
This Section is about The Theatrical Stage Employees that have become Injured or Profoundly Ill while working on location at Downey Landing's Downey Studios in Downey, California. In this section you will be able to review a great deal of the material, including having the opportunity to view medical documentation.

INDEX DOCUMENTS AND SYNOPSIS OF MATERIALS -
PRESENTED MOST RECENT FIRST

Downey audio report by Adolfo Guzman – Lopez 89.3 KPCC Radio Reporter And Jerry Blackburn of NASA - General information on the site.

List of Legal Events in order of most recent first with the exception of May 7, 2007 showing background of illness:

May 7, 2007 - Barry Bernson, et al vs City of Downey, Downey Studios LLC - The Lawsuit - Background on what happened and the medical symptoms/complaints.

Feb. 15, 2008
Notice of Errata - Request to allow media in the court room.

January 31, 2008
Plaintiffs - pro per
Transcript of Proceedings

January 17, 2008
This historic site that the government still says is unclean land with a polluted water table where a lot of became sick is now slated to be torn down and have homes built upon it.
mirrored at:
http://downey.kaiserpapers.info/
newhomes.html

November 13, 2007
TIERRA LUNA (DOWNEY STUDIOS) REIMBURSEMENT AGREEMENT

November 13, 2007
Citizens in City Council Meeting are
concerned with possible conflict of interest
of Downey Studios Tierra Luna Development

2007
Government correspondence regarding which agencies are appropriate to file suit against.

October 23, 2007
REPORTER'S TRANSCRIPT OF PROCEEDINGS

October 23, 2007
Opposition to DreamWorks Demurrer

October 23, 2007
Opposition to Boeing Demurrer

October 23, 2007
Opposition to City of Downey Demurrer

October 23, 2007
Exparte Ruling

October 23, 2007
Memorandum of Points and Authorities

October 23, 2007
Reply Memorandum in Support of Defendant the Boeing

October 23, 2007
Hearing on Demurrers

October 22, 2007
WESTERN ANALYTICAL LABORATORY TEST REPORT - The Lead Environmental Report

October 16, 2007
WESTERN ANALYTICAL LABORATORY TEST REPORT - Asbestos

October 9, 2007
Boeing Co. Declaration of Kathryn L. Oehischlager

August 24, 2007
REPORTER'S TRANSCRIPT OF PROCEEDINGS

June 21, 2007
Order Granting Attorney's -

May 9, 2007
Filing against the GSA

April 25, 2007
Court Reporter's Transcription of the settlement between Downey Studios LLC vs International Alliance of Theatrical Stage Employees, International, International Alliance of Theatrical Stage Employees,Local 44, and Ronnie Cunningham, an individual and does 1 to 100, inclusiveVC045585 .

May 26, 2006
Motion to Amend Complaint to Add Additional Defendants (by Plaintiff Leonard Martin)

October 10, 2005
Medical Lab Reports for Leonard Martin

September 2, 2005
Claim for Damages

August 4, 2005
Medical documentation of Leonard Martin who became ill while working on site at Downey Studios. - This information is provided to show what some of the medical reports on individuals have discovered.

July 2005
Two News Article regarding cases.

May 4, 2005
Letter from Local 44 explaining about the toxins and mold found at Downey Studios.

April - June 2005 discussion of mycotoxins and mold at Downey Studios.

April 11, 2005
Blog entry regarding the resultant legal activities

March 24, 2005
Letter from DreamWorks regarding having environmental testing done

March 3, 2005
Environmental Report generated for Dream Works - limited scope

Medical Claim Form

Article found online related
to this material

As this is a Public Service Web Site we have provided links to General Information regarding some of the diagnoses of individuals that have become ill while working on the former Downey Facility Property. This is not all inclusive, is not for you as a patient to diagnose but is something that if you think it applies to you, can mention or print out for your physician to review.

Radioactive materials were used in Building 1. Only one small portion of Building 1 was cleared for radiation and that area is not near where the reported illnesses have developed.

General Information of the signs and symptoms of radiation sickness may be found at:
http://en.wikipedia.org/wiki/
Radiation_poisoning
and
At The Mayo Clinic
http://www.mayoclinic.com/health/
radiation-sickness/DS00432/DSECTION=2


Mold and Fungi and related organisims do thrive on old material and toxic substances.

Some General Information of the signs and symptoms of mold or fungal diseases may be found at:
http://www.biosignlabs.com/
Symptoms_Mold_Sickness.html
and
http://www.mold-survivor.com/
symptoms.html

This is a very short synopsis to bring everyone up to date and to clarify what is known to have taken place, and did result in illness to many people:

We have no first hand information before 2003. There is historical documentation of what projects were performed prior to 2003.

There were three separate groups of people employed on the property at different times that have become ill. Several different movie productions and film companies were involved.

In or around September of 2003 something happened on the property in Building 1 that began causing illness for a great number of people working at that location.

Buildings 290 and 6 may have something to do with these illnesses.

During the time period 2004-2005 numerous people, became ill in Building 1 from what originally was thought to be illness exclusive to mold and mycotoxins. Note: Mold and mycotoxins are nearly always found at locations of toxic contamination. It has been formally established that great numbers of molds and mycotoxins at the time of testing were found to be present.

At that time Union 44 was sued by IRG for putting the employees on notice that they could become ill while working on this property. Because of that lawsuit a gag order was reached and a settlement was reached between the parties involved stating that that no matter what the outcome of the environmental report that the Union would say it was a safe place to work. - see: http://downey.kaiserpapers.info/injured/downeyvslocal44.html

In 2006, at the then just opened Kaiser Medical Building, adjacent to Building 1, Building 290 and Building 6, and 288, employees from the Kaiser building began developing illnesses with the same symptoms as the Theatrical employees.

It has been reported but not yet confirmed that more people are still becoming ill. 100% of these people sound very, very ill, now do have neurological problems linked to their exposure which has made it sometimes difficult to sort out the facts.

This web section is an attempt to put in order what did take place and get these people some help. Because all of these people initially filed worker's comp claims their initial medical reports indicate that they all have neurological problems and suffer from fibromyalgia. Some have been fortunate enough to have finally received more complete medical treatment. Most have not. Not all information regarding diagnoses are placed on this page for reasons of confidentiality, and for purposes of not overstating fact.

In the following lawsuit please consider that as these profoundly ill people have had to navigate the court system on their own at their own expense and for the most part without legal representation, that many have dropped out of the case. They simply cannot afford it. They are still ill.

The following is some historical background on the resultant case between Downey Studios, DreamWorks and the Union.

" Downey Studios/DreamWorks is Being Targeted for a Major Class-Action Suit that May Cost the Studio Millions and Shorten the Lives of Hundreds of Their ..."
http://www.icommag.com/july-2005/july-west-coast-insiders-hotline.html See:
http://www.icommag.com/july-2005/july-west-coast-insiders-hotline.html

"At Downey several workers on "The Island" complained of health problems, allegedly from exposure to mold and other toxic substances. Downey dismissed the claims as spurious, citing outside tests that gave the facility a clean bill of health. It sued the workers' union, alleging that it spread false information. The union has been negotiating to settle the case."
http://johnnydeppreads.com/ar/t202.htm


A page in Southern California Aerospace History turned last month, NASA transferred it over to the City, the plant in Downey, that turned out, the Apollo Space Craft, and parts of the Space Shuttle. The 160 acre site will be the new home for a complex of movie sound studios, stores, a hospital, and a museum, focusing on the sites role of air and space exploration, KPCC Adolfo Guzman – Lopez, took a tour of the site.
Please listen to the program and read the transcript at:
http://downey.kaiserpapers.info/injured/adolfoguzman.htmlFebruary 15, 2008 - Notice of Errata
LEONARD JAMES MARTIN, IN PROPRIA PERSONA files a Notice of Errata; MOTION TO ALLOW MEDIA IN THE COURT ROOM and MOTION TO AMEND COMPLAINT TO ADD ADDITIONAL DEFENDANTS
http://downey.kaiserpapers.info/injured/amended.html
The Boeing Company Declaration of Kathryn L. Oehlschlager 10-09-07
Information on historical buildings and declaration made by Boeing Representative.http://downey.kaiserpapers.info/injured/kath.htmlApril 25, 2007
This is a court reporter's transcription of a settlement agreement between Downey Studios and International Alliance of Theatrical Stage Employees, Local 44.

Downey Studios, LLC, filed suit against Plaintiff, Local 44. This document references an environmental report that was made by an unnamed company. The request is made by Downey Studios that whatever the results of the environmental testing that the Union will now acknowledge that Downey Studios is now a clean and safe place to work and will resume the practice of sending business to said Studio. Downey Studios also demanded a settlement paid to them in the amount of $775,000.

Downey Studios LLC vs International Alliance of Theatrical Stage Employees, International, International Alliance of Theatrical Stage Employees, Local 44, and Ronnie Cunningham, an individual and does 1 to 100, inclusive VC045585 .
http://downey.kaiserpapers.info/injured/downeyvslocal44.html
Government correspondence regarding the appropriate agencies to file suit.

These are two letters regarding the suits that were filed, including the GSA and The Department of The Interior. The GSA letter dated May 23, 2007 is in regards to the 42 Tort Claims submitted by Attorney Mark D. Apelian. The GSA writes that the incorrect government agency has been contacted.
In the second letter , Mr. Stewart of The United States Department of The Interior is writing about the Downey Studios Administrative Claims pursuant to the Federal Tort Claims Act. Mr. Stewart is requesting that NASA be the lead government agency in this case.
http://downey.kaiserpapers.info/injured/governmentletters.html

October 23, 2007
REPORTER'S TRANSCRIPT OF PROCEEDINGS
http://downey.kaiserpapers.info/injured/october232007.html

October 23, 2007 - Document showing Opposition to DreamWorks Demurrer with referenced material to Environmental Study conducted.
http://downey.kaiserpapers.info/injured/oct232007oppositiontodreamworks.html
October 23, 2007 - Opposition to Boeing Demurrer

http://downey.kaiserpapers.info/injured/oppositiontoboeing.html

October 23, 2007 - Opposition to City of Downey
http://downey.kaiserpapers.info/injured/oct232007oppositiontodowney.html
October 23, 2007 - Exparte Ruling of October 23, 2007
http://downey.kaiserpapers.info/injured/noticeexparterulingoct232007.html
October 23, 2007 -
PLAINTIFF LEONARD J. MARTIN’S OPPOSITION TO THE IRG DEFENDANTS’ NOTICE OF DEMURRER AND DEMURRER TO PLAINTIFFS’ FIRST AMENDED COMPLAINT; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF
http://downey.kaiserpapers.info/injured/oppositionIRGdemurrermemorendum.html
October 23, 2007
Hearing on Demurrers To First Amended Complaint
http://downey.kaiserpapers.info/injured/firstamended.html
Reply Memorandum in Support of Defendant the Boeing Company's Motion to Dismiss Plaintiff's First Amended Complaint for Failure to Join Indispensable Party
http://downey.kaiserpapers.info/injured/boeingmotiontodismiss.html

August 24, 2007

REPORTER'S TRANSCRIPT OF PROCEEDINGS

http://downey.kaiserpapers.info/injured/august242007.html

June 21, 2007
Order Granting Attorney's Motion to be Relieved as Counsel - Civil
Mark D. Apelian, Esp, Bernson v. City of Downey, et al.
http://downey.kaiserpapers.info/injured/apelian.html
May 9, 2007
Legal Filings Against the General Services Administration of the United States
http://downey.kaiserpapers.info/injured/gsafiling.html
The following is the revised lawsuit . This provides the background for what took place while these people were working at Downey Studios.

Barry Bernson, et al vs City of Downey, Downey Studios LLC, Industrial Realty Group, Los Angeles Center Studios, Ezralow Company, Dreamworks Pictures, Entertainment Partners, national Aeronautics and Space Administration, Boeing, VC 046716
http://downey.kaiserpapers.info/injured/thelawsuit.html
September 2, 2005
Claim for Damages to Person and Property in Complaince with California Gov. Code 911.2
http://downey.kaiserpapers.info/injured/claimfordamages.htm

May 4, 2005
Letter from Local 44 explaining that the testing showed mold and other toxic exposure injures that they should be concerned about.
http://downey.kaiserpapers.info/injured/themoldletter.html

Discussion of mold and mycotoxins present at Downey Studios that took place between April 2005 and June 2005
http://downey,kaiserpapers.info/injured/mycotoxindiscussion.html

April 11, 2005 in Work

This is the letter that I got in the mail today:

To: Island Cast and Crew
From: DreamWorks Production Safety
Subject: Downey Studios Stage Issues
We hired an independent testing company to conduct a series of environmental tests at the Downey Studios on March 03, 2005. In the buildings known as the mill, stage 1, and 290 we tested […]

http://filmhacks.wordpress.com/2005/04/11/
March 24, 2005 Letter from DreamWorks regarding the Mintie Report. Mintie Report included in this html page:
http://downey.kaiserpapers.info/injured/themintiereport.html


March 24, 2005 letter from DreamWorks
To the Island Cast and Crew
Jim Economos- DreamWorks Production Safetv
Regarding the Downey Studios Stage Issues
http://downey.kaiserpapers.info/injured/pdfs/dreamworks%20letter-1.pdf


March 3, 2005 - Environmental Report written for DreamWorks specific to discovery only of mold and no other substance by Wayne Hanson of The Mintie Corporation - Health Science Association.

Document 1 - http://downey.kaiserpapers.info/injured/pdfs/report 1-3-1.pdf

Page 2 Laboratory Report specific only to mold:
http://downey.kaiserpapers.info/injured/pdfs/report 2-3-1.pdf

Page 3 - Laboratory Report specific only to mold:
http://downey.kaiserpapers.info/injured/pdfs/report 3-3-2.pdf


From: http://veryangel.cn/index.php/work/24194/so-very-uncool-totally-unauthorized

This is the letter that I got in the mail today:

To: Island Cast and Crew

From: DreamWorks Production Safety

Subject: Downey Studios Stage Issues

We hired an independent testing company to conduct a series of environmental tests at the Downey Studios on March 03, 2005. In the buildings known as the mill, stage 1, and 290 we tested for the presence of mold spores. The tests came back positive for several kinds of mold.

We have attached a copy of the report we received on March 23, 2005 from Minte Corporation, the independent testing company, which specifies which specific molds were present and the levels at which they were found. Minte informed us that a normal healty individual, with this period of exposure, should not have been adversely affected by potential exposure of this type. However if you have a compromised immune system, are pregnant, or have any other concerns, you may want to consult with your physician.

I am available to answer any questions that you may have. If you think you have been affected by this exposure please inform the production and consult your physician.

The letter is attached to about 10 pages of graphs and charts that, of course, I don’t understand. I seriously doubt I’ve got any ‘health issues’ (and if the only XXXX up thing there was mold, it’ll be a miracle. Downey Studios used to be a military facility, and there are stories of green glowing dirt and barrels of toxic waste), as I was only there for two days, but it’s still unsettling.

I’m not sure if I prefer this new, more responsible film industry over the old one that just said “Hold your XXXXX breath if you’re worried about the shit in the air”.

It might be worse knowing. When you don’t know, you can’t worry about it.

We all worked for years at the Ambassador Hotel, which is full of every kind of asbestos ever made, and never gave it a thought, until someone said “Hey, that stuff XXXXX your lungs up! You should be wearing a respirator”. Now I worry about my lungs.

Yup, definitely worse knowing.

http://veryangel.cn/index.php/work/24194/so-very-uncool-totally-unauthorized

KAISERPAPERS.INFO

downey.kaiserpapers.info