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IN THE SUPERIOR COURT FOR THE DISTRICT OF COLUMBIA CIVIL DIVISION JOANNE BARURA, et. al,. * CIVIL ACTION NO. Plaintiffs, * vs. S.E.W. INVESTORS, a/k/a/ S.E.W. PARTNERS, et a~l. * * * N Defendants * * * * * * * * * ~tQR 2 0 * st~~. C... D: me Ri~fut * PLAINTIFFIS SECOND AMENDED DESIGNATION OF EXPERT WITNESSES * * Plaintiffs, by their undersigned counsel, hereby designate, pursuant to Rule 26(b)(4) of the Superior Court Rules of Civil Procedure, the following additional person as an expert witness. Plaintiffs incorporate, in this Second Amended Designation, Plaintiff's Amended Designation of Expert Witnesses previously filed with the Court. 1. Rosalind C. Anderson, Ph.D. - Dr. Anderson's resumd, which sets forth her background and qualifications, is attached hereto as Exhibit A and incorporated by reference herein. She currently holds the position as President, Anderson Laboratories, Inc. ("Anderson"). Dr. Anderson is expected to testify as follows: Based on tests conducted by Anderson and her review of other data, Dr. Anderson will state it is her opinion that the air in the Waterside Mall is currently contaminated, and more probably than not was contaminated for some time in the past. She will further state that the contaminents may have O• j Cb ISSUE 46 j~j?APPENDIX B ~ ~

adversely affected the muscular, neurological and respiratory systems of the Plaintiffs. Dr. Anderson will testify that when tested the air in the building adversely affected the muscular, neurological and respiratory functions of mice, and the detrimental effects on mice directly correlate to detrimental effects on humans. The contaminants were measured by the American Source Test Material Consensus E-981 Method. This is an accepted consensus standard. Dr. Anderson will further state that based on the tests conducted by Anderson, and other data she has reviewed, it is her opinion that the air in the Waterside Mall Complex, currently is unacceptable, as defined by ASTM standards and worse than other public buildings around the country and in the D.C. area. Dr. Anderson will testify that tests conducted by other consultants in the Waterside Mall Complex did not measure the effect of contaminants on EPA occupants. Specifically, these tests did not measure the toxic effect of complex mixtures at different concentrations. Consequently, the test results often did not reflect that the building was contaminated. If the results were measured via the ASTM E-981 Standard, they might have indicated that this building was and is contaminated. Dated: March 1, 1993 ll~et4 t4~-, Robert W. Kat D.C. Bar No. 1413 (SIGNATURES CONTINUED ON NEXT PAGE] ~ ~ ~ - 2 - O CA a C.7 W

Gordon, Feinblatt, Rothman, Hoffberger & Hollander 233 East Redwood Street Baltimore, Maryland 21202 410/576-4291 Attorneys for Plaintiffs CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this day of /4-1 r'`1 1993, a copy of the foregoing Plaintiffs' Second Amended Designation of Expert Witnesses was mailed, first-class, postage prepaid, to: Gregory A. Krauss, Esquire Carr, Goodson & Lee 1919 Pennsylvania Avenue, N.W. Washington, D.C. 20006; James W. Greene, Esquire Bromley, Greene & Walsh 1050 17th Street, N.W. Washington, D.C. 20036; Edwin Sheridan, Esquire Doherty, Sheridan & Gramalbi 8408 Arlington Boulevard, Suite 200 Fairfax, Virginia 22031; Marc L. Fleischaker, Esqurie Arent, Fox, Kintner, Plotkin & Kahn 1050 Connecticut Avenue, N.W. Washington, D.C. 20036-5339; 3

L31256.550 S:5 Mark Proctor, Esquire Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, P.A. P.O. Box 12308 226 South Palafox Place Pensacola, Florida 32581; and Bernard J. DiMuro, Esquire DiMro, Ginsberg & Lieberman, P.C. 921 King Street Alexandria, Virginia 22314 Jonath N. Portner ~ 4