Any interrogatory, request for admission or production utilizing this term is necessarily overly broad, over burdensome and calls for information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.

Defendant further objects to the definition of these terms as calling for the production of material or information which is not relevant nor reasonably calculated to lead to the discovery of admissible evidence.

Defendant further objects to the definition ofthese terms as calling for the production ofmaterial or information which is not relevant nor reasonably calculated to lead to the discovery ofadmissible evidence.

Defendant further objects to the definition ofthese terms as calling for the production ofmaterial or information which is not relevant nor reasonably calculated to lead to the discovery ofadmissible evidence.

Defendant further objects to the definition of these terms as calling for the production of material or information which is not relevant nor reasonably calculated to lead to the discovery of admissible evidence.

Defendant further objects to the definition of these terms as calling for the production of material or information which is not relevant nor reasonably calculated to lead to the discovery of admissible evidence.

ASARCO generally objects to any interrogatories and document requests seeking information as to entities other than ASARCO on the grounds that such interrogatories and requests are overly broad, unduly burdensome, and seek information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. 8.

Defendant further objects to the definition of these terms as calling for the production of material or information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.

Defendant further objects to the definition of these terms as calling for the production ofmaterial or information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.

TAI CHANG Arrival Date: ANALYTE SPECIFICATION RESULTS Identification Loss on Ignition (1000 C) Acid-Soluble Substances Reaction and Soluble Substances Water Soluble Iron Arsenic Heavy Metals Lead Microbial Limits Total Bacteria Count To Pass Test < 6.5% < 2.0% <0.1% To Pass Test < 3 ppm < 0.004% <0.001% < 500 per g Passes Test 6.11% 0.77% 0.034% Passes Test 0.16 ppm < 40 ppm 1.17 ppm < 10 per g Productlon/Asbestos Identification A.

Defendant objects to this request as it is overly broad and unduly burdensome and it calls for material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.

Defendant objects to this request as it is overly broad and unduly burdensome and it calls for material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.

ERI must provide training to all their employees based on the As, Cadmium, & Lead Standards.

The investigators are leading experts in their fields.

The investigators are leading experts in their fields.