Union Carbide further objects to this Interrogatory on the grounds it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence.

i 1 { j 5 t*- i ri I LEAD INDUSTRIES ASSOCIATION O AT TCT n c w romc it . h . r.

According to the court, fully informing women of the dangers of lead exposure would allow them to make informed choices about working in a high lead environment, without barring women from jobs for which they are otherwise qualified.

BERNIE'S WORK EXPANDED WITH THE ADVENT OF LEAD REGULATION IN 1993 AND HE BECAME THE "RESIDENT EXPERT" FOR SITE FOR ASBESTOS AND LEAD.

December 29, 1992 PROFS Note LAST UPDATED ON 08/21/1992 BY EMPLOYEE NUMBER 00106979 Page 3 (1) P0631726 - BD3010 STARS Course Catalog List 12/22/1992 10:15 PAGE 3 ORGANIZATION: 25 MANUFACTURING & TECHNICAL PAY CENTER : 0141 SOC-DEER PARK MANUFACTURI COURSE NUMBER: BD3010 COURSE TITLE: S-125 (CLASSROOM) ASBESTOS TRAINING AUTHOR/VENDOR: SHELL COST: 0 INACTIVE DATE: // DURATION DAYS: 0.00 HOURS: 1.00 NOTIFICATION LETTER: LEAD TIME ( OCCUPATION CODE: TARGET GROUP: ALL DPMC EMPLOYEES EVALUATION CALL-UP PERIOD (WEEKS): APPLICABILITY: FAIR LABOR STANDARDS ACT: COURSE TYPE: Video/Film PREREQUISITES: * NONE FOUND * KEYWORDS DEFINED: ASBESTOS S-125 MANDATORY COURSE DESCRIPTION: THIS ASBESTOS TRAINING WAS DEVELOPED BY DPMC AND TVM AS PART OF THE HASIP MONTHLY SAFETY PROGRAM.

The Thomas Flyer, leading the way, took a boi to Alaska, but the wealher conditions there were even more severe, and no progress at all was possible.

The Company attributes its leading market position to the following competitive strengths: (l) well-known brand names, many of which are the leading brands m their category; (li) broad range of product offerings within both the premium and mass market segments of the United States cigar market, (m) commitment to and reputation for manufacturing quality cigars; (iv) marketing expertise and close attention to customer service, (v) efficient manufacturing operations; and (vi) an experienced management team The Company is also a leading producer of pipe tobacco and is die largest supplier of private label and branded generic pipe tobacco to mass market retailers.

*L'al#r, the report could lead`to'sigalficant changes in policy.

THERE IS NO DOCUMENTATION HAT POTABLE RATER SYSTEM IS LEAD TREE".

Objection is also made to the extent these interrogatories assume the truth of matters not established, and on the grounds that they seek information which is not relevant to the subject matter of this lawsuit and not reasonably calculated to lead to the discovery of admissible evidence.

Union Carbide further objects to this Interrogatory on the grounds it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence.

Union Carbide further objects to this Interrogatory on the grounds it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence.

The a American / Ceramic ' Society , s February 15,1993 I hereby certify that the attached copies of Ceramic Abstracts, Volume 19,1940, are true and accurate copies, which are maintained in the normal course of business at the American Ceramic Society, 735 Ceramic Place, Westerville, Ohio 43081.

RESPONSE: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome, as well as beyond the scope of discovery permissible under the Missouri Rules of Civil Procedure in that it does not seek discovery of a matter relevant to the issues raised by the claims or defenses of any party and the information sought does not appear reasonably calculated to lead to the discovery of admissible evidence.

S TO: FROM: DATE: SUBJECT: Distribution /1fJ____Max Hekmat fiyfj January 25, 1990 1990 I.