This obviously arises curing leading of the mix buggies from the hoppers and to c leseer extent during shifting and transfer cf the wheeled containers. 1- -

cases and are not reasonably calculated to lead to the discovery of admissible evidence.

Walker Vice President-Sales, Lead Chemicals lagle-Picher Industries, Inc.

This practice increases the potential for lead ingestion. 75*26 Provide ear plugs or other approved hearing protective devices for employees working in areas where permissible durations of exposure are exceeded.

Abex further objects to this interrogatory on the ground that it purports to shift the burden of establishing causation from plaintiffs to Abex Abex objects to this interrogatory to the extent it purports to seek information or materials regarding time periods and products that are not at issue in these cases, on the ground that such information or materials lack relevance 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 m these cases and are not reasonably calculated to lead to the discovery of admissible evidence Abex further objects to this interrogatory on the grounds that it assumes the truth of matters not established or matters not in evidence.

Facts About Lead and Pediatrics.

., Manager .Environmental Health International Lead Zinc Research Organization, 292 Madison Avenue New York, New York 10017 Inc.

Several of the asbestos samples collected from locations pro cessing lead compounds were also selected for analysis to determine airborne lead concentrations at various operations.

| aa the cancers in both lead major error SALES AT RECORD HIGH ~ JRAERE

LUNG CANCER IS LEADING KILLER IN MEN NOW, AND WILL BE THE LEADING KILLER IN WOMEN IN THE 1980'S.

Secretary, National Lead Company FROM ,, L.

Unleaded PER CENT Leaded PER CENT How long would it take to accomplish these reductio s?

Several of the asbestos samples collected from locations pro cessing lead compounds were also selected for analysis to determine airborne lead concentrations at various operations.

- Lead profile Initiated January 1972

Further objecting, the information sought is neither relevant to the subject matter of the pending action nor reasonably calculated to lead to the discovery of admissible evidence as it relates to Dana.