,,was, injured; . through the use' of gasoline containing tetraethyl lead.

I shall be much interested in your results on the question of lead in water.

I agree with you that reloading, or the giving of milk, is no excuse for having bad hygienic conditions in a lead plant.

first* the Standard Oil Company of Indiana,{and perhaps other companies) has issued In structions which on their face appear to apply specifically to leaded gasoline* It would seem bad policy to openly state that they.have done this on their own responsibility although the latter is the case* Second* the Initial regulations published by the United States Public Hedfcth Service have not been officially modified* and so far as I know the Service has not put:itself on record as approving of our discontinuance of leaflets of Instructions and regu lations at filling stations* `Eheir point of view In this is similar to mine* I am not sure that they would publicly agree with me on the record If for no other reason than that they would consider.too-close an agreement between us as bad policy* 'Wo might* therefore* appear to have neglected the carrying out of the regulations if I were to state specifically that we had not Issued any kind of Instructions* I do not believe all this Is of great importance* but X have been very cautious in replying to this gentleman because I have not wished to get us Into any awkward position* I have taken the trouble* therefore* to express what I have said about It as my own personal opinion without saying anything about the practices and responsibilities of the Ethyl Gasoline Corporation.

Finally, the interrogatory seeks information over a broad span of time and seeks information that is irrelevant and immaterial and not reasonably calculated to lead to the discovery of admissible evidence.

GM objects to this request because it is vague, overly broad, unduly burdensome, and not likely to lead to admissible evidence.

Further, the interrogatory is overly broad, general and global and seeks information which is irrelevant and immaterial to any issue in this lawsuit and is not reasonably calculated to lead to the discovery of admissible evidence.

Interrogatory No. 70 is objected to on the 12 grounds that it is overly broad, vague, ambiguous and unintelli 13 gible with respect to the use of the undefined word "arched." 14 Additionally, the interrogatory calls for information which is 15 not reasonably calculated to lead to the discovery of admissible 16 evidence. 17 INTERROGATORY NO. 71: 18 Is defendant aware of articles authored by W.

Further objecting, the information sought is neither relevant to the subject matter of the pending action nor reasonably calculated to lead to the discovery of admissible evidence as it relates to Dana.

Yant's interest in industrial hygiene has been ascribed to his co cern for "any activity which would lead to greater health, comfort and safety f' human beings. " His plans were large and as a result millions of workers in ir try have benefited by his untiring efforts to safeguard their health.

ARnrvr CROPS OPERATING PROTIT: Tooele Lead Plant Tooele Copper Plant Tooala Sulphide Concentrator Ulaal Plant Total Add - Ulaaallanaoua Inaoaa Total Teduet Bad Detota 2xpan.

As a general rule, it is not considered necessary to make tests e^efty time the men are examined; in fact, it is our present nding thg/tf these tests are not necessary unless an individual has er symptoms of lead-poisoning ana, of course, should you run across an 'Individual in that condition, you would naturally notify us irnmedi^etj^and w\_w^uld probably ask you at that time to conduct the necessary uiftn^sari&dysis \p>support your previous diag nosis, but nothing like this shouldNobv o^ne in the general routine examina tions which you carry out each quai^ei [iscussions with you, it was agreed that we would pay you a standard fee of\5\Vguilders per year for your work on our behalf, and it was expected that suet ?

To the extent this interrogatory seeks information concerning the working conditions of Abex employees, it is objected to on the grounds that such information lacks relevance to this case and is not reasonably calculated to lead to the discovery of admissible evidence.

. _ may have had a considerable exposure to load* In my opinion this would be a matter of secondary importance but It seems pertinent to me to inquire into the extent of such exposure, in as much as It is conceivable that such an exposure may have been a contributing factor In a general lack of resis tance to an infectious process* The heart condition is un doubtedly of the latter type and in my opinion It Is the sole cause of his present disability, I shall make a later report of the lead findings if there is anything of significance to report.

To the extent this request seeks materials related to the working conditions of Abex employees, it is objected on the grounds that such information lacks relevance to this case and is not reasonably calculated to lead to the discovery of admissible evidence.