It. 20 L.LO A Lavjrsr lock# at Lead j Theodor* C.

LIA08808 yil.lrbiii LEAD INDUSTRIES ASSOCIATION 4*0 LimUTOH tMW rn m M m rn m w m v 'w w w 9.

RESOLVED, that the proposed expenditure of the sum of $2400. by Evans Lead Company for new roofing on south side of its Charleston Plant, in conformity with letter of Mr.

for tlus Easton Lead dispoetion.

Based on their interpreta tion of thia tire,-1 relationship, tine should have sold in January 1951 st about 11# a pound and lead at 13i#.

Jl mj, mi ---------- lead reference sheet (part I) H.

Johnson, Bowman and Knox Serial Number 178,352 Piled December 6, 1937 Por: Method of Producing Vfhite Lead Dear Mr.

Bearlum Metal Description - Leaded bronze: bar or casting.

Jl mj, mi ---------- lead reference sheet (part I) H.

You know, d o u b t le s s , t h a t we in t h is la b o r a t o r y have s t u d ie d th e problem o f le a d exp osur e and le a d a b s o r p t io n in r e la t io n to lead ed ga s o lin e in alm ost ever y con ce iva b le way over a p e r io d o f a lm ost fi ft e e n y e a r s , and i f we have e r r e d -in our o b s e r va t io n s and co n clu s io n s * I t is time we were d is co v e r in g our e r r o r s . ..

" /a LEAD INDUSTRIES ASSOCIATION at LeciMOTOM AVKMUC mw tom *, N.

The situ ation , th e r e fo r e , in volves d an ger, an d the in dividual sh ou ld n ot be p e r m it t e d to b e su b je ct e d to fu r t h e r occu p ation al exp o su r e to lead le st he becom e ill.

Further, this interrogatory seeks an answer which would require speculation by the defendant, and" is not reasonably calculated to lead to the discovery of admissible evidence.

lead reference sheet (part I) JTtmylrm U.

RESPONSE: Defendant objects to the form and substance of this request on the following grounds: 1. the request is overly broad; 2. the request is unlimited in terms of time; 3. the request in unlimited in terms of geographic scope; 4. the request is vague; 5. the request is ambiguous; 6. the request is multifarious; 7. the request seeks information which is not relevant and which is not reasonably calculated to lead to the discovery of admissible evidence; 8. the overly broad nature of the request is such that it would be unduly burdensome and prohibitively expensive to gather the information necessary to respond to this request; and, 9. the request exceeds the scope of discovery permitted by Rule 166b of the Texas Rules of Civil Procedure.