PITTS & ASSOCIATES
Attorneys at Law
_________________________________________________________________________
8866 Gulf Freeway, Suite 117
Houston, TX 77017-6528
(713) 910-0555
(713) 910-0594 (Fax)


March 26, 2004

Dear Gulf War Veteran client:

On August 19, 2003, a class action lawsuit was filed on your behalf in Federal Court in Brooklyn, New York against the bank defendants and supplier defendants that we can assert personal jurisdiction over in New York. A copy of the lawsuit text is listed on the litigation website, which is at: "www.gulfwarvetlawsuit.com".

Any future status reports will be on that website, "www.gulfwarvetlawsuit.com". If you do not have the internet, any public library will be able to get you on the internet to check the site. If you have an email address, or if your friends or family have an email address, you or they should go on the website, hit "Enter" and then scroll down the column on the left side of the page and register your e-address under "subscribe to Update Report." This is to ensure that you get notice of updated information in the future.

It generally takes two and a half to three years to get to trial in the Federal Court in Brooklyn, which is technically known as the United States District Court for the Eastern District of New York. We have no reason to delay bringing your case to trial. Twenty-nine of the bank defendants, through their eleven defense law firms, recently filed a joint motion with the Court in New York to dismiss the veterans' lawsuit concerning the banks, as a matter of law. A copy of our response brief , filed last Friday, is posted on the litigation website. Oral argument to the Court on the banks' joint motion will occur on May 21, 2004, and the Court will render a written opinion some time thereafter.

It appears that we will not be able to get jurisdiction over BDH Ltd. in New York. Beyond that, five of the remaining nine supplier defendants in the N.Y. case (i.e.: De Dietrich, Georg Fischer, Fluka, Sulzer, and Lenhardt) are asserting, through motions to dismiss, that they have not done enough business in New York to be properly sued there. We have asked the Court to allow written discovery and depositions of the defendants' corporate representatives before these motions are considered by the Court.

In the Texas case there have been favorable depositions of witnesses and favorable discovery of documents concerning Alcolac International, one of the two substantial U.S. defendant suppliers of chemical precursors. There was one other chemical supplier company from the U.S., Al-Haddad Trading. It was run by an Iraqi national that fled after the First Gulf War. He was arrested in Bulgaria on an Interpol warrant from Germany a few months before the Second Gulf War, because he was engaged in smuggling into Iraq goods that were banned by the U.N. sanctions. His U.S. company became defunct when he fled the U.S. after the First Gulf War.

One of the defendants mentioned in the Iraqi documents, Klockner, has been held to not be able to be sued in Texas because of inadequate business contacts with the State. We have appealed the District Court's ruling on this.

Any settlements in a putative class action will have to be approved by the Court, after a hearing. There have been no settlements yet.

Since my April 25, 2003 status report, there have been several research developments:

May 2, 2003 - The journal Science reported that scientists have found that eggs may be grown in the laboratory from existing embryonic stem cells, possibly avoiding the need for controversial donor eggs. Stem cells can grow into virtually any cell in the body. Researchers are suggesting that they could be used to grow new brain cells to revive or repair brain cells that have been damaged (such as by exposure to Iraqi chemical warfare agents).

June 3, 2003 - The Washington Post reported that Congressional researchers recommended to Congress to ask the Pentagon to triple the number of U.S. troops presumed to be exposed to chemical warfare agent fallout from the Iraqi Khammisiyah depot demolition in March 1991 to 350,000, or roughly half of U.S. forces that served in Gulf War I.

June 4, 2003 - The Associated Press reported that researchers have found that children of veterans of the First Gulf War are more likely to have three specific birth defects than those who never served in the war. The infants were found to have higher rates of two types of heart valve defects, tricuspid valve insufficiency and aortic valve spinosis. They also found a higher rate of genital urinary defect, hypospaedia, in boys conceived after the war to Gulf War veteran mothers. In addition they found that Gulf veterans' children born after the war had a certain kidney defect, renal aegenisis, that was not found in Gulf War veterans' children born before the war.

June 16, 2003 - The High Court in London refused to overturn a ruling that officially recognized for the first time the existence of Gulf War Syndrome. British Medical Journal, 326:1350.

August 8, 2003 - Reuters News Service reported that U.S. researchers found that anti-depressants (fluoxetine [Prozac] and tricyclic imipramine) may help stimulate the growth of new brain cells. New anti-depressants may be developed to target this process directly.

August 15, 2003 - Medscape Medical News reported the results of a double-blind, placebo-controlled trial published in the October 22, 2002 issue of the Proceedings of the Royal Society: Biological Sciences. The research showed that supplementation with 5 grams of creatine daily improved working memory and intelligence. "Previous studies, as well as anecdotal reports, suggest that creatine supplementation can increase sports performance and could potentially be useful in treating neurological, neuromuscular and atherosclerotic disease. Brain creatine levels have been shown to correlate with improved recognition memory and with reduced mental fatigue." If you consider using any of this research yourself, please discuss this with your doctor, especially as it applies to extended use and the necessity of drinking adequate water if taking any creatine.

September 23, 2003 - Two medical studies, one by the V.A., and one by Dr. Robert Haley, at U.T. Southwestern, were published in Neurology. They confirmed that veterans of the First Gulf War have an increased risk of developing the neurological disorder, ALS, otherwise known as Lou Gehrig's Disease. Dr. Haley concluded in earlier studies that the neurological brain damage in Gulf War veterans was caused by exposure to chemical warfare agents. The V.A. has recognized ALS as coming from exposures during the First Gulf War.

An environmental epidemiologist, Mary Joyce, has a book pending publication entitled: ALS, MS and Our Toxic Environment (Merrimack Journal Publishing, Dracut, MA) which may be of interest on the ALS and MS issues.

March 17, 2004 - Reuters News Service reported that the Pentagon has granted $240,000 to a Swedish team for stem-cell research. Lund University in Sweden said the U.S. Dept. of Defense was supporting the study concerning Parkinson's Disease "because the findings could be used to treat similar neurological illness caused by battlefield toxins" (i.e.: Gulf War Illness symptoms caused by exposure to nerve gas).

A very important fact, that will become even more obvious as time goes on, is that there is no widespread multi-symptom neurological disorder ("Gulf War Illness") from the Second Gulf War. Though U.S. troops were in the same theater of operations, with the same heat, sand, dust, stress, injections, and even some oil fire smoke - they are not ill, certainly not tens of thousands of them ill in a way compatible with chemical agent exposure. The only significant difference, healthwise, between the First and Second Gulf War is that there were chemical agent exposures in the first war, and none in the second war. This will be noticed and commented on as time goes on.

In addition to the 52 supplier companies listed in my April 25, 2003 status report letter (a copy of which is on the website under "Update Letters"), and the 36 banks sued in New York, there are other companies and banks mentioned in the Iraqi Full Final and Complete Declaration ("FFCD"). In order to let you know all of them, the following is a list of every one of them that have not been previously named in the Texas or New York lawsuits or in my 4/25/03 status report. These are all of the remaining companies and banks that appear to any degree in the Iraqi documents concerning the Iraqi chemical weapons program, along with a summary of the reference to them. Many of the companies and some of the banks are no longer in business. We have not been able to get personal jurisdiction over the surviving additional banks that are not named in our New York lawsuit, and the vast majority of the surviving additional companies. In the rare instance where a company is still in business and we could possibly get personal jurisdiction over it and have not sued it, we decided that it is not economic to add it as a defendant given the specific limited nature of its involvement. For example, with the suppliers of the rockets and shell casings, there is no medical causation link between Gulf War Illness and the rockets and shells themselves, minus the chemical warfare agents.

In alphabetic order, the other companies and banks given any mention in the Iraqi FFCD consist of the following:

Banks:

Al-Ahli Bank of Kuwait Kuwait
Amman Bank for Investments Amman, Jordan
Banca Di Sicilia Rome, Italy
Banco Exterior De Espana Madrid, Spain
Bank of Boston Int. New York
Bank Handlowy W. Warszawie Warsaw, Poland
Bank of England London, England
Bank of Valleta Ltd. Valleta-Malta
Banque Commercial de Luxembourg Luxembourg
Banque De France Paris, France
Berliner Handels und Frankfurt Germany
Central Bank of India India
Commerze Bank Düsseldorf & Mannheim, Germany
Creditanstalt Banken Verein Vienna, Austria
Credit Commercial de France France
Credit Lyonnais Bank Netherlands Netherlands
Girozentrale Vienna, Austria
Gothard Bank Lugano Switzerland
Hypo Bank Munich, Germany
Islamic Development Bank Jaddah, Saudi Arabia
Manufactures Hanover Trust Germany Germany
Midland Bank PLCr London, England
National Commercial Bank Jaddah, Saudi Arabia
Perwira Habib Bank Kuala Lampur, Malaysia
Post Och Credit Banken Luxembourg
Qatar National Bank Doha, State of Qata
Rafidain Bank London, England and Amman, Jordan
The Gulf Bank Kuwait
UBAE Arab German Bank Frankfurt, Germany
UBAF Bank Ltd. London, England
UBAF (Hong Kong) Limited Hong Kong
Union de Banques Arabes et Francaises (UBAF) Seoul, Korea
United Commercial Bank India

Suppliers:
Name of Company Location of Supplier,
Where Stated
Product or
Service Sold
Ab Groedernexbergs (Sweden) pipes & fitting
Adobade (Germany) belts
AHB Technoco Merz (unknown) spare parts
Ahrens (Germany) valves
Aiax (Italy) spare parts and spare for cooling
Aldasa (unknown) distillation unit
Aldrich (unknown) chemicals. Sigma Aldrich is a defendant in the Texas litigation
Alexander (Germany) pressure gage
Allweiler (unstated, believed
to be Germany)
pumps & spare parts
Al-Mashini (Jordan) polyethylene canister and mold for canister
Al Sharef (Egypt) supply and erecting supplies
Apparatepaue (unknown) heat conveyer unit
Arescon (Bahrain) D.30 TM device
Armstrong (U.K.) spare parts
Ase (Belgium) freon cylinder
Auda (unknown) erection of chlorine plant
Aviv Blomedical (New Jersey) spectrophotometer meter
Bayer (Germany) refused to sell chemicals to Saddam
BDH Ltd (UK) lab chemicals
Bemenco (Argentina) raw materials; but Saddam's agents' attempts to buy precursor chemicals from the company failed
Best Corp. (Japan) air conditioners
Bobinindus (Belgium) spare parts
Boehringer (Germany) lab chemicals
Boneventure Co. (Switzerland) special material, no agreement reached on rocket warhead
Braith (U.K.) water tanks
Brand (Germany) spare parts
Busc (unknown) spare parts
Busch (unknown) spectronic instrument
Cabot (unknown) condensers, and heat exchangers
Carmel (unknown) refused to sell chemicals to Saddam
Ch. Abstracts (unknown) micro film services
Chronpack (Netherlands) N2 generator
Ciba Geigy (Switzerland) material, equipment, acid resistant paints
Cogelex (France) electrical stations
Companies, Inc. (Panama) precursor chemicals
Coulter (U.K.) counter for particle size, spare parts
Daikin (Belgium) air conditioners & spare parts
Degussa (Germany) Saddam's agents requested the company to submit an offer for choline chloride, and they never did. The attempt to procure chemicals was then abandoned.
Derman Diesel (U.K.) generator, spare parts
Devaints (Belgium) spare parts
Don Gresswell (U.K.) library equipment
Dow Corning (German division) equipment & litheam-800
Dr. Schaler & Longe (Netherlands) technical equipment
Duker GmbH (also referred to as
"Dueker" or "Ducker")
(Germany) pipes & heat exchanger
Eeer (France) drainage network, air washers, & spare parts
Eivs (France) technical and scientific equipment, pumps and spare parts
Endress-Hauser (Germany) humidity meter
Engico (Germany) vacuum cleaner
Enterprises or
Interprise
(Brazil) chemicals
Esab (Dubai) welding machine
Euroclima (Italy) cooling equipment
Europlast (unknown) p.e. tubes
Expal (Spain) aerial bomb parts
Festo (unstated, but believed
to be Germany)
spare parts
F.G. Bode Co. (Germany) glass equipment
Foxboro (Jordan, but main headquarters in Germany) control unit, control & measurement system, instrumentation equipment, flow meters, valves
FSL Int. (U.K.) spare parts
Fredrichsfeld (unknown) pumps, spare parts
Geka (Germany) oil electrical gases
Glaswerk Werthein (Germany) raw material and manufacturing glass & apparatus
Grand fos (Demark) spare parts
Greschbach Industrie (Germany) chemicals, and equipment
Guhring (Germany) drills & screws
Hahn & Kolb (Germany) equipment
Heinrichs (Germany) flow meters
Herause or Heraous (Germany) analyzer, ovens, air press, heating tape, spare parts
Herbert Arnold (Germany) machine & technical equipment
Hewlett Packard (Branch in Switzerland) data process units, computers
Hib Flour Co. (Germany) representative for Heberger Co.
Hohenbrun (Germany) chemicals (by L/C 250/3/82)
Hoxid (unknown) fork lift
ICI (U.K.) refused to sell chemicals to Saddam
Intereyim (France) pumps
Iutz (unknown) vertical pump
Jakob Thaler (Germany) tools
Jetraco (Germany) spare parts
Joseph Bertsch (unstated) thermal oil plant
Jou annt (France) lab device
Karl Lutz (Germany) pumps
Keramchemie (Germany) anti acid tiles, lab equipment, composite material & bricks, tower production, & material for gas system
Klinkhart Co. (Germany) balances, 5 ton
Knoedler (unknown) spare parts
Kosan (Denmark) equipment for filling bombs
Krupp (Germany) lathe tools
KSB (unstated but believed to be Germany) pumps
KSU (Switzerland) car lift equipment
Labsco (Germany) lab equipment
La Carbonne Lorrana (unstated but believed to be France) heat exchangers
Lanceses Link Co. (Switzerland) chemicals or Lanceslink
Lansing (U.K.) forklift, and spare parts for it
Le Telmecanique (France) analyzer device
Libherr (Germany) cranes & spare parts
LKB (unknown) electro phorecess, & spare parts
Lummus (U.S.) lab and gas chromatography equipment
Magnetrol (unknown) equipment
Mantech (Kuwait) computer, spare parts, accessories for print machine
March May Co. (U.K.) pumps
Markarte (unknown) "50 suit"
Marleye (U.S.) towers spare parts
Massafindou (unknown) pumps & spare parts
Mecs Int. (Japan) micro film sys.
Meinburk (Germany) inspection & communication equipment
Merk or Merck (Germany) chemical material
Messer Giescheim (Germany) welding machines & equipment
Mettler Instrumente (Switzerland) lab device, temp. analyzer
Midland (unknown) pumps, spare parts
M.K. Juchhelm (Germany) spare parts
Monteflor (unknown) refused to sell chemicals to Saddam
Montodeson (Italy) refused to sell chemicals to Saddam
Motivair (U.K.) spare parts
Motor Air (unknown) air compressors
Munchi (unknown) chemicals
Munsch chemie (Germany) spare parts
Neuman (Germany) spare parts
Norenco (China) mortar shells, rocket motors
Nukraft (unknown) this company worked as a broker concerning Alcolac, which is a defendant in the Texas litigation
Nuway Energy (U.K.) fire cement, "civil & tools equipment," spare parts, "erecting burning"
Ochsner (Germany) spare parts
Orlita (Germany) pumps, spare parts
Packard (Netherlands) gas chromatograph
Parkfame (U.K.) spare parts
Paul Hedfeld (Germany) pumps, and spare parts
PBD (Italy) artillery shells and rockets
Perol (Sweden) emulsifiers
Perkin-Elmer (U.S.) gas chromatograph, I.R. equipment, spectrophotometer, spare parts
Pfaudler (France) reactors, and heat exchangers, condensers, columns and tanks
Pharmacia (Sweden) lab chemicals & material
PHB (Germany) shelves for cooling equipment
Phoenix (Germany) valves, pumps, & teflon tubes
Pigant (France) distillation unit
Pilot Plant (Germany) a very significant supplier that was involved in construction of the chemical agent production facilities. This company is out of business.
Polyma (Germany) generators, H.T. equipment, spare parts
Premus (Sweden) gas cylinder
Purpack (Germany) scrale instrument
Quast or Qusat (unknown) reactors, heat exchangers, condensers, and vessels
Quinton (unknown) technical equipment
Remeco (unstated, but believed to be the Netherlands) pressed air cylinder
Richter (Germany) heat exchangers, valves, spare parts & materials
Rideldehein (Germany) chloroamin and lab chemicals
Ritz (Germany) pumps, spare parts
Ruston Diesel (U.K.) generator, spare parts
Rycoft (U.K.) air compressor, spare parts
Sabic Company (Saudi Arabia) 16 tons of ethylene glycol sold in 1987. An attempt to buy ethylene oxide in 1987 was dropped because the chemicals were unsuitable.
Sabroe (Germany) valve relief
Sakar (Egypt) rockets
Sandvik (Sweden) lathe tools
Scabert Hoizon (unknown) chemicals
Schuchardt (Germany) chemicals (by L/C 250/182)
Servio Co. (Cyprus) Saddam's agents' attempt to buy chemical precursors from the company failed.
Sica (Belgium) flow meter unit
Siemens (Germany) head testing unit
Sihi Co. (Germany) pumps and spare parts
Sinia (unstated but believed to be Italy) artillery shells and rockets
Sitac (unknown) mechanical equipment, and erection of water treatment station
Sofraf (unknown) industrial equipment
Sommer (unknown) reactors
South Wales (U.K.) spare parts
Sumitomo (Japan) cars
Supelco (Switzerland) lab equipment and materials, spare parts for water sweetener units, & tank analyzing materials
Supped Co. (unknown) lab equipment
Talabac (Hong Kong) special equipment
Taylor (unknown) instrumentation equipment
Telenorma (unknown) operator, spare parts
T.E.T. (Germany) pumps, spare parts, tech. pressure reducer
TMC (Germany) contract to deliver white phosphorus was cancelled
Trane (unknown) cooling equipment
Tsa Aussenhaend (Germany) catting machine
Uhde (Germany) chlorine plant
Umivergeltredling (unknown) chemical material
Unic (U.K.) animal unit
United Phosphorus (India) an expert came to explain procedure for analysis of PCL3 & POCL3
Universal Trading Co. (Canada) Saddam's agents' attempts to buy precursor chemicals from the company failed.
Vicarb (unknown) heat exchangers
Vitalograph (U.K.) medical equipment
VFF Co. (unknown) tower packing & ball ring
Wallaettie-Rnan (unknown) spare parts
Warmald (Hong Kong) fire extinguisher, supply erection, forklift, and heat sensors
Wesper spare parts, metal discs (unstated but believed to be France)
Wernerl-Puperm (Germany) pumps & spare parts
W.E.T. (Germany) This company is no longer in business. It was a (Water Engineering Trading) significant supplier.It provided precursor chemicals and a chemical factory, reactors, heat exchangers, condensers, columns, hallar vessels, pipes, pumps, spare parts, lab equipment, filling and other equipment, and an electrical power station.
Winkelmantt (unknown) tanks
Winter (unknown) gas leak detector
Wisley Huges (unknown) maps, designs
Wreyand (Germany) spare parts
W.T.B. Co. (unknown) construction of three integrative production sites
Yokohama (Japan) spare parts
York (U.S.) spare parts
Zeiss, Carl (Germany) microscope
Zekom (unknown) steel equipment
Zetiler (unknown) spare parts
Please note that the statute of limitations in Texas and New York is two years from the date of negligence or discovery of the negligence and the connection with the resulting personal injury. The statute of limitations time may be shorter or longer in other states or countries. We obtained the Iraqi documents in September 2002, so the statute of limitations may run out on any additional defendants in Texas or New York near the end of August, 2004. We have only committed to suing the companies and banks that are in the current litigation in Texas and New York. Feel free to contact other counsel, in any jurisdiction, about suing any of the companies or banks that we do not currently have in litigation.

The National Gulf War Resource Center will host its eighth annual national conference on April 30 - May 1, 2004 in the Washington, D.C. area. The conference will be at the Holiday Inn, 2650 Jefferson Davis Highway, U.S. Route 1, Arlington, Virginia 22202, (703) 684-7200. You can review the conference itinerary and register to attend at http://www.ngwrc.org.

I shall file another status report as there are any significant developments in the litigation, or any medical breakthroughs that occur in regard to the treatment of Gulf War Illness.

We appreciate the opportunity to represent you in this important matter; and again thank you for your service to our country.


Very truly yours,

PITTS & ASSOCIATES


Gary B. Pitts