Lead Co. sulfur dioxide study.

Abex further objects to this interrogatory to the extent it purports to seek information or matenals regarding time penods and products that are not at issue m these cases, on the grounds that such information or matenals lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence Abex objects to this interrogatory on the grounds that the information or matenals it purports to seek otherwise lack relevance to the issues ansing in these cases and are not reasonably calculated to lead to the discovery of admissible evidence Abex also objects to this interrogatory on the ground that it assumes the truth of matters not established or matters not in evidence Subject to and without waiving these objections, and insofar as Abex understands this interrogatory ANSWER TO INTERROGATORY NO. 37 SUBPART (aV.

Lead War n i n g Figns- S-ept. 18, 1946 For your information ve are attaching several copies of a letter regarding lead warning signs which was sent to all our customer companies on Sept e m b e r 6.

Vie have in our pos session most of your former writings on the general subject of lead poison ing, and since there is some possibility the^m^case will be tried this fall, we would appreciate being furnished with a copy of the above described paper in order that we may prepare ourselves as fully as possible for a discussion of the case with you at a later date in the event it is to be tried.

This man worked for a period of three years in the h a n d i n g of gasoline containing tetra-etnyl lead.

In New York, the company said ,the plant was closing "because we are abandoning that type of manu facturing.1' The plant makes zinc oxide and white- lead.

Has lead line.

Abex also objects to this interrogatory to the extent it purports to seek information or materials regarding time periods and products that are not at issue m these cases, on the grounds that such information or materials lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence To the extent it purports to seek information or materials regarding the working conditions of Abex employees, this interrogatory is further objected to on the grounds that such information or materials lack relevance to the issues arising m these cases and are not reasonably calculated to lead to the discovery of admissible evidence Abex objects to this interrogatory on the ground that it assumes the truth of matters not established or matters not in evidence.

Abex objects to this interrogatory on the grounds that the information or materials 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.

Bear Bob t I have shipped to you express a sample of sludge and sealer taken from a wing tank of one of Eastern Airline* s planes.Vfould you please analyze for lead content and advise me of your findings, I am sure you will find it very low in lead content but it will help me in my work with Eastern Airlines, I will give you a complete report of my { work as soon as this problem is solved.

Htrltwi Copper tforkei Refining Departnent Secondary Beasxtment Lead Refining Department Zinc Oxide Departoent '-'hite lead Department yitcellaneout Income Ifonth of January, 1941 35.JOO 136,0;* 16.265 13.12!

Three visits were made to the plant to check toxic hazards and asbestos, lead formate, potassium, etc.

Is it possible to have lead analysis made, within your company, on the blood, urine and feces of our employees working with leaded substances?

Abex also objects to this interrogatory to the extent it purports to seek information or materials regarding time periods and products that are not at issue m these cases, on the grounds that such information or materials lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence To the extent it purports to seek information or materials regarding the working conditions of Abex employees, this interrogatory is further objected to on the grounds that such information or materials lack relevance to the issues arising m these cases and are not reasonably calculated to lead to the discovery of admissible evidence Abex objects to this interrogatory on the ground that it assumes the truth of matters not established or matters not in evidence.

In my opinion it excludes any possi bility that lead absorption was a factor in Mr.