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

Mils lead \ fl'irl - Hr. 2.

Walpole, Assistant General Counsel SSL, h#i (f*-'i /,*' :t,V 'V RE: EPA - CDC Study on the Effects of Smelter Emissions on Children JA :x Last year the Environmental Protection Agency and-the Center for Disease Control conducted a nationwide survey on heavy metal absorption in children living near primary copper, lead, and zinc smelters.

Abex further objects on the grounds that, in seeking information concerning products to which the plaintiff does not allege her decedent was exposed, this interrogatory lacks relevance to this case and is not reasonably calculated to lead to the discovery of admissible evidence.

Interrogatory No. 120 is objected to on the 16 grounds that it is overly broad, vague, ambiguous, burdensome and 17 calls for information which is not reasonably calculated to lead 18 to the discovery of admissible evidence.

Although you were not being monitored on April 5, 1975, our employee injury report leads us to believe that you were exposed in excess of the permissible vinyl chloride exposure limit, i.e

. - 1,1 glit degradrtion - This information from Bloomfield need:- )-o u. brought i.oge i v, MONS 096683 Will Ralph pleace lead the revaluation of the chlorine and FR level and will Scott and Ralph put the story together on biodegradation.

Sb $n Pb Ce.K.S re Zn highest very high moderate low to moderate low very low uncertain This suggests that alxture of tin aercaptlde and lead compounds are present as PVC stabilizers.

Veenis: In my capacity as Chairman of the Nominating Committee for Directors of the Lead Industries Association, it is my pleasure to invite you to serve as a Director in the forth coming year.

This is a very significant contribution to the data on lead in human beings.

GM objects to the rest of this interrogatory because it is vague, ambiguous, overly broad, burdensome, and is not reasonably calculated to lead to the discovery of admissible evidence.

Samples were analyzed for trace amounts of the following metals: lead, iron, zinc,'chromium, nickel, cobalt, copper, manganese, and aluminum.

Abex also objects to this interrogatory on the grounds that in seeking information concerning Abex employees, it lacks relevance to this case and is not reasonably calculated to lead to the discovery of admissible evidence.

Because plaintiff has failed to identify exposure to any asbestos-containing products of this defendant, this interrogatory is further objected to on the grounds that it lacks relevance to this case and is not reasonably calculated to lead to the discovery of admissible evidence.

"We hope this state wifi lead the nation In banning PCB," the commission said in a statement.