Kehoe:- In connection with the case previously brought to your attention of a farm water well contaminated with leaded gasoline from a Shell Oil Co. of Canada, Ltd. bulk plant;, we have received some additional data.

1 RESPONSE TO INTERROGATORY NO. 82: 2 No. 3 INTERROGATORY NO. 83; 4 Please state the names and addresses of all distribu tors and companies to which the defendant sold or distributed 5 asbestos or asbestos-containing products for the years 1930 to 1972. 6 RESPONSE TO INTERROGATORY NO. 83: 7 Wagner objects to this interrogatory on the grounds 8 that it is overly broad, unduly burdensome, and not calculated 9 to lead to the discovery of admissible evidence and seeks pro 10 prietary business information. 11 INTERROGATORY NO. 84; 12 Please state whether defendant has knowledge of any 13 material which could be or is being used for the same purpose as asbestos.

I note your criticism of the proposed hypothetical question which has to do with the air analyses made in the plant and the quantity of lead which such analysis showed.

MaioaaHPQM FOR MBSCTOBS' SESTING - MaBCH 2gTH I535 STOaTSD ssr IHCUMS - aiSLTIHC DSPAgXKaiT CBOSS OPERATING PROyiT: Tooele Lead Plant Too*!

When I ar r ive d a t th e o ffic e yester day I t r ie d t o ge t Sam Wagner on th e teleph on e but I was un able t o do so as he was in San Diego where th e r etir ed n aval o ffice r died, but I le ft certain in form ation regardin g a le t h a l dose of t e t r a e t h y l lead at our Los Angeles o ffic e fo r t r an sm ission t o Wagner .

-'amainst entering any storage tank, there is no mention of-leaded gasoline storage tanks or any other one type tank. lyhave endeavoured to have such letters include all^tahkahto avoid calling unnecessary and unfavorable attentlon^'to an;rIdasard'that might exist In connection with our nro/uets. '\.\/ the second letter attached,in which jour regulations are quoted,, is addressed to maintenance men only, iliese five men are responsible for all tam:\cleaning/vork and are the only men that are to enter / tanfcsv-^ V

:srvw33> met znaaa - l e ib s o t min o . z in c c u d s 4.d ^h it c tap imimEMrs LEAD FSTINIUG DSPaRVH KTi Operating Iocoaa Less - lap re elation NET INCMS ZINC CKID3 DKPAHTT.FNT: ralaa of Vine Oxide Coat of 7al Leaa - ' hutdown Xpenaea - . kroa ilant Leaa - lapraoietion end ObHolteoaaca irsr in c are Pounds of Zinc Oxide ' old Salta Frlca Coat of sales youth of ilarcii 19*0 i 6,000 4#ioa : 1,5QU Month of Tebrawy 15*0 4 W.721 *.355 10,366 Three Hoe. ended :*tr. 31 tt 19*0 35,0*6 12, *96 ' .-22.550 5165,026 iii2L i 8.551 350 ; 8,201 2.620 5 5,581 5122,617 1*8.310 5 : ,u >3 --------- 21 t - 2.2*70 ^ 8t^4C. 2,757 , 9*5 5.7116 5,6016 2,368,760 5.9706 6,1756 f44$,426 *38.101' 4 7.325 *77 5 6,828 7.158 7,53*,7*5 5.9116 5.8146 "HITS LSA7J rSPAHTMKOT: r.ftlaa of Laad Products Coat of r.alaa Laaa - Ptpraclation NLT INC OKA Found a of Laad Producta ."

RESOLVED, that the proposed expenditure of the Siam of $430. by National-Boston Lead Company, in addition to turn-in allowance on old car replaced, for the purchase of a Ford Tudor car for salesman, in conformity with letter of Mr.

.; Pacific Coast Distributor : `National Lead Company of California, 2240 24th Street, San Francisco, Cal,?

1 RESPONSE TO INTERROGATORY NO. 16: 2 Wagner objects to this Interrogatory on the grounds 3 that it is not confined to any relevant time frame, is vague in 4 that it does not define "design changes" and is not confined to 5 the issue in this case or calculated to lead to the discovery of 6 admissible evidence and is therefore overly broad and unduly 7 burdensome.

Beeves brought up Suggestion Ho* 5 for the White Lead Depart ment aa Mentioned ia Messrs* !

.; Pacific Coast Distributor: National : lead/Co. of CaRfomia, 2240 24th it^Bet, Son Francisco, Cal.; Canadian Distributor: iVihan, Patersbn, Gifford, Ltd., 10T Murray Street, Sf Helen's Aveque, Toronto, Ont. 1 jfr This adverthetfetiiiappedrs id the fallotyingpplyliciition,::-' % PPSe> bidis Rubber'World,-Jenuaicy,1932 - ' v rK^500 N 28272 *' n I it,;; & I;

Fin Type Radi ator Concealed in Cabinet Chapter 9--Steam Heating Systems and Pipe Sizes supply mains shall be above these mains, or that there shall be a drainage connection consisting of a trap or of a pipe leading to the wet return, depending on the type of system, above these supply valves.

ANSWER TO INTERROGATORY NO. 17: Abex objects to this interrogatory 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.

The term "occupational disease," as used in this act, means only the following diseases: (a) Poisoning by arsenic, lead, mercury, or manganese, their prepara tions or compounds, in any occupation involving direct oontact with, handling thereof, or exposure thereto.