(f) Abex objects to this subpart on the grounds that it is overly broad, burdensome, lacks relevance to this case and is not reasonably calculated to lead to the discovery of admissible evidence. 9- -

See also Further objecting, this interrogatory is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence.

Anaconda Dry White Lead hipped from Sc*ark, N.J., to Mateo W&rehonoe Co., Loe Angeles, California, per S.S.

Bockstahler (1971-11/1981) Defendant objects to the remainder of this interrogatory for it is overly broad and unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence.

/alburn Petroleum' Company CentIsmen: 'Inis is to advise you that there has been a claim entered against us through the Industrial Accident hoard of the State of Yassaehusetts by the Y/idow of one of our chauff eurs who has just died of leukaemia which she attributes, by authority of the hospital doctors, to lead poisoning.

Crudgington*s examinations he did not feel that these men show any signs of acute lead intoxication at this time, but he felt that there was a definite hazard in carrying out the work as it has been done formerly.

Kehoe, Will you be good enough to send me as soon as you conveniently can, a list of questions which might be put to one of the plaintiffs in these cases for the pur pose of determining whether he has any of the symptoms of tetra ethyl lead poisoning?

discovery of admissible evidence Abex also objects to this interrogatory on the grounds that the information or matenals it purports to seek otherwise lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the discovery of admissible evidence.

I appreciate very ranch what you have said and understand fully your situation as consultant in this case* I shall correspond further with Doctor Johnston about the matter* In his correspondence with me thus far Doctor Johnston appears to be convinced that this Case is one of lead poisoning.

Ordway, Department of Physiology, School of Public Health, Boston, Mass, My dear Miss Ordway; You were very kind to take so much trouble in getting the lead poisoning literature for me.

Philadelphia) Js (National Lead & On Co, Pittsburgh) ` - ' *v\l "ii r sSgSSA :i*Vl.

Vertrees Colorai^&boasts one of the country's ; leading day-busters.

reasonably calculated to lead to the discovery of admissible evidence; (f) Abex has been continuously qualified to do business in the State of Pennsylvania since June 1924; (g) The registered agent for service of process for Abex Corporation is the Prentice-Hall Corporation System, Inc. ; (h) Abex objects to this interrogatory on the grounds that it is vague, ambiguous and lacks particularity as to what information is being requested; ' ------- (i) No. 5.

(f) Abex objects to this subpart on the grounds that it is overly broad, burdensome, lacks relevance to this case and is not reasonably calculated to lead to the discovery of admissible evidence. 9- -

In addition, this interrogatory seeks information concerning time periods and products not at issue in this case, and Abex further objects on the ground that such information lacks relevance and, therefore, is not reasonably calculated to lead to the discovery of admissible evidence.