The following is a summary of operations at the Shite Lead PJ.ant- for the above period: .'

National Lead Company 111 Broadway New York 6, New York NL 000040208

;interrogatory is objected to on the grounds that such information or materials lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the discovery of admissible evidence.

Abex also 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. -125-

Average number cells in operation Lbs, White Lead per D.C.K.W.

Shite Lead per D.C.K.W.

\ c^ ) noaically you have been checking men in our employ ho have had Industrial exposure to lead.

Kehoe:- I cannot adequately express my appreciation of your very interesting letter with it's wealth of information on the subject of lead poisoning and particularly concer/ning the problem of tetra-ethyl lead in gasolene This confirms much of my study of the matter and affords specific facts that I know will be extremely useful in the case:: that is now coming up and in future ones of like nature As you so clearly stated my interest is not in winning the case, and I want every claimant under the Workmen's Compensation Act to receive whatever is properly due him under the laws, but I do believe that if there is no -merit in such a claim that every effort should be made to prevent the accumulation of erroneous decisions that might tend to establish ISe the toxity of lead in gasolene, if as a matter of fact such a thing does not exist.

White Lead per D.C.K.W.

Abex also 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.

(street) Detroit (city) NAME OF this plant: Acme White Lead & Color Works Address of this plant: ,8250 St.

leal P iritaa - Refinery - Secondary Lead - lbs.

COPY LEAD INDUSTRIES ASSOCIATION 420 Lexington Avenue New York 17, New York March 29th, 1949 George H.

July 19, 1940 Mr* Hugh Fossett The Associated Ethyl Company Ltd* The Adelphi London, W* C, 2 England Dear Mr* Fossetfcs Quit some time ago I received your letter with respect to the request of the Distillers Company for a supply of tetraethyl lead for carrying on some work, tha nature' of which is not disclosed'* As a matter of principle, I can see no objection to supplying tetraethyl lead to competent technical people who will make proper use of it under adequate conditions of safety* It is quite clear that if they are not able to obtain it from on source, they will from another* There is, therefor, no reason why your company should not supply such material for legitimate use.

Abex also 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. -125-