True It-d Lead- 2E2L Iron OrlA .

lead acid battery wfck a top (peed */ d?

In 1827, 18 or It) plants molting white lead wore combined to fora what *an tnen the "National Lead Truet".

Defendant further objects to this Request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.

Defendant further objects to this Request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.

Ill White Lead National Lead Co. 107 HTS White Lead Pure Dry Lead Basic Lead Carbonate 109 Ti-Pure YCR Titanox AA National Lead Co.

Pieher Lead Co Pttre Sulphate of Lead.- Trace of Oxide.of Lead. 5 - 10$ Oxide of Zinc.

American vermilion is basic chromate of lead.

Zurn objects to any Discovery.Request which requests information that is irrelevant and is not reasonably calculated to lead to the discovery of admissible evidence. 7.

Quality lead pu ("VONE are the days when lad ` ^ Pipe was just lead pipe.- ' T<K* & day you can buy lead -pipe that is quality marked--stamped with the famous Dutch Boy trade-mark and the name of National Lead Co.Tabkam.

FROM EUSTON LEAD COMPANY r I K PURE LEAD PIGMENTS 500 PENH AVE,t SCRAlftON/eENNA., U.

CO., Philadelphia NATJONAL LEAD & OIL CO..

*I hire'-'lead -.'

Inasmuch as there is no evidence that Borden ever sold or delivered VCM to plaintiff decedent's employer's Pottstown facility, Borden objects to this request for production on the grounds that, as to Borden, it is unduly burdensome, oppressive, overly broad and seeks irrelevant information which is not reasonably calculated to lead to the discovery of evidence admissible with respect to Borden.

K' f LEAD INDUSTRIES ASSOCIATION 410 UCnNOTON AVXNUO MCWTOAK IT, N.