Document 37r2BJg2xonXdBdj0p5e6k66E
Without waiving these objections, see Response to Interrogatory No. 39.
43. Please state the names and addresses of all persons employed by defendant from 1930 until the present time who functioned as industrial hygienists. As contemplated by these Interrogatories, an industrial hygienist is one who per forms engineering or health studies to identify, and evaluate potential occupational health hazards id suggest methods of dealing with same. Please state:
(a) The facility or of ..'ice to which they were assigned and the inclusive dates.
(b) responsibilities.
Their complete and precise duties and
ANSWER: Abex objects to this Interrogatory on the
following grounds:
1. 2.
Burden Overly Broad
3. Lack of Relevance
Without waiving these objections, Abex states as follows:
1941-1945 1943-1954 1945-1946 1946-1966 1948-1948 1949-1954 1951-1951 1952-1955 1955-1966 1955-1960
J. B. Littlefield H. J. Weber R. H. Anderson H. Gotmer W. A. Hamlin A. Edwards R. A. Myles D. Carlson J. S. Holtaway J. T. Siedlecki
Address for above group:
2501 S. Blue Island
Avenue, Chicago, Illinois 1941-1956.
-28-