Further objecting, the request is overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence as it relates to Dana.

ELECTRICAL DESIGN Two electrical engineers, one functioning as lead engineer, did the electrical design.

S' LIA23329 LEAD INDUSTRIES ASSOCIATION, INC.

ELECTRICAL DESIGN Two electrical engineers, one functioning as lead engineer, did the electrical design.

WHITE LEAD PAINT 1/4 NO.

ELECTRICAL DESIGN Two electrical engineers, one functioning as lead engineer, did the electrical design.

ELECTRICAL DESIGN Two electrical engineers, one functioning as lead engineer, did the electrical design.

M.

ELECTRICAL DESIGN Two electrical engineers, one functioning as lead engineer, did the electrical design.

SUMMON* IN A CIVIL ACTION

This Defendant objects to providing answers for any other period of time on the grounds that such additional information is irrelevant, immaterial, not calculated to lead to the discovery of admissible evidence and, furthermore, could be burdensome, expensive and harassing to comply with.

.1. ~1k 1 union carsio .c.9i'o.;;.r:nN CHEMICALS AND PLAS"I* o OPERATIONS DIVISION ENGJNEERINC f/EP^R TMENT PLAINTIFFS EXHIBIT \ II 0C-P-131 PROJECT C--JNITION: INSTRUMENTATION DESIGN BASIS ETHYLENE OXIDE SEADRIFT, TEXAS (0 *?

National Lead Company National Sand f.

Inc. 1938 Vesuvius Crucible Comcany 1934 Lead Industrie* Association 195* London Transport Board 1937 Viatmam/HampOen Grinding Wheel Co. 1962 Louisians Army Ammunition Plant 1937 Wasmngion Mills Abrasive Co.

I have suggested cutting out all of that sentence as being entirely misleading, without interrupting, otherwise, the biographical account. 1 trust that my remarks above and in the attached statement will not lead you to believe that I do not give this biography a good rating.