Simon Baruch, a leading pioneer in the field.

._ -g^~. ..ou-m s-^A^--l IA216(>5 LEAD INDUSTRIES ASSOCIATION GrayW (jJiog, 420 Laxlngtoa Avanua Naw Yo*t, K.

The information requested is not rele 17 vant and not reasonably calculated to lead to the discovery of 18 admissible evidence. 19 INTERROGATORY NO.

-F'AJmn^rs L>.D HEyiKDC DEPAHIMUfT: Croaa Profit Dapraoiatloa Hot Ib o o m 7.IHC onHE nEPARTMFKTs Salat of Zina Oxida Cost of riN Inoona - Bafcra spr*clatiott Oapraalatlon Not XaooeM Pound* of Zina Oxld* Sola Salat Prioa Coat of sio 'TUTS LEAD DEPARTMHfTi Salta of Load Pro&Mta Coat of Salat InootM - Bafora Dapraolatioa 0ST.itlOB Nat Inecna Poona* mt L*a Pol* ?

0B DIRECTORS* SHEETING - JANUARY 26TH 1937 NET INCOME - LEAD REPINING, ZINC OXIDE AND '*HITE LEAL DEPARTMENTS LEAL REFINING DEPARTMENT: Gross Profit Depreciation Nat Income Month of Month of Daocaber November 1936 1936 <,500 * 5,175 800 11 * M *_iiS2 Twelve Months Twelve Months ended December ended December 31t 1936 31st 1935 < <2,782 13.225 < 29,557 < <9,089 ___ li<l9. < 38,600 ZINC OXIDE DEPARTMENT; Seles of Zinc Oxide Coat of Seles Insane - Before Depreciation Dprolatlo Nat InocoM <3<0,1 <285,159 378.809 llill 4 36.388 < <0,806 5.100 4 <2,567 < <5,906 <3,099,<29 3 ,<95.267 < 395.838 57.068 < <52.906 <2,926,291 2,6.<0,5<5 4 285,7<6 <9.722 < 236,021 Founda of Ziao Oxlda Sold Ssl Is s Prlea Coat of Ssl Is s WHITS LEAL DEPARTMENT: S.l*. of L.d Froduat.

On card No. 2 all the tanks should be reported, both those used for blending at any time and those which have only been used for the storage of leaded gasoline at blending points.

In the schools held m 1976 through * 14 the present, minimization of dust creation was discussed in 15 regard to minimizing the workers' potential exposure to free 16 asbestos fiber. 17 INTERROGATORY NO. 57: 18 If the answer to Interrogatory No. 56 is in the affir mative, please state: 19 (a) The date and place of such meeting, seminar, 20 conference or convention; 21 (b) The name and address of the speakers. 22 RESPONSE TO INTERROGATORY NO. 57: 23 Wagner objects to this Interrogatory on the grounds 24 that it is overly broad, unduly burdensome and not calculated to 25 lead to the discovery of admissible evidence. 26 INTERROGATORY NO. 58: 27 Has the defendant ever warned any labor union or its representative of the potential health hazards associated with 28 the use of products containing asbestos?

literature, Aa you are aware# there has been a certain looseness In the use of these limits in that sometimes they are spoken of in terras of the quantity of lead which presumably may be inhaled per day* whereas sometimes they are given in terms of quantities per 10 cubic meters of air, X made the mistake in this instance of thinking that you had used the figure of approximately 1,5 milligrams in reference to the daily intake by inhalation rather than In terras of the quantity in a known volume of air, I have since recognized the mistake and have corrected it wherever the opportunity has presented itself, The error# I believe# was explanable though not quite excusable# and I am sorry that it has occasioned any difficulty of any kind, 2 can assure you that in ray own. practical work* I have considered that the concen trations in air should be under 2 milligrams per 10 cubic meters.

As a consequence of this state of affairs, it is now quite clear that if the present conditions and precautions are maintained, we need not anticipate occupational lead poisoning from this source.

It calls for information which is immaterial and irrelevant to any issue in this lawsuit and it is not reasonabiy calculated to lead to the discovery of admissible evidence.

I shall be much interested in your results on the question of lead in Sincerely yours, g e /l r j t / F.

Kehoe s Since we last talked to you with respect to the potential lead hazard through the develop ment of the special metals, we have had some test bars made which have been submitted for the machin ing qualities.

Kuen has lead poisoning.

Further, 20 the interrogatory seeks information which is not reasonably cal 21 culated to lead to the discovery of admissible evidence.

Joseph Lead Company . . 500.00 1,000.00 Sales of Symposium Bock . . 1.2S7.79 96.00 United States Gypsum Company . . 2,687.50 112.50 In memory of Sydney Lunt Wood: Miss Sarah C.