Defendant objects to the stated definition of the terms "products containing asbestos fiber," "asbestos containing products" and "asbestos products" on the grounds it is overly broad, vague and not limited to the matters made the basis of this lawsuit and therefore, seeks disclosure of information and/or the production of documentation wholly irrelevant to any material issue in this case and not reasonably calculated to lead to the discovery of admissible evidence.

The Metallic Lead Products Division was aeant to cover finished or easi-finished products of Ir.dJ.etry rather than such 1 x&a aaterials* as pi( lead or 'antisonial lead'*.

S OBJECTIONS TO PLAINTIFF'S NOTICE OF CR30(b)(6) DEPOSITION- 2 4218898.1 Williams, Kastner & Gibbs PLLC 601 Union Street Suite 4100 Seattle, Washington 98101-2380 (206) 628-6600 1 RESPONSE: 2 JMM incorporates herein its Preliminary Statement and General Objections and further objects to this request on the following specific grounds: the request is overbroad, 3 overly burdensome, lacks foundation and is not reasonably tailored to the facts of this case, and seeks information and documents that are not relevant or reasonably calculated 4 to lead to the discovery of admissible evidence.

The lead operator must start the re covery and monitor its progress from the control room.

S OBJECTIONS TO PLAINTIFF'S NOTICE OF CR30(b)(6) DEPOSITION- 2 4218898.1 Williams, Kastner & Gibbs PLLC 601 Union Street Suite 4100 Seattle, Washington 98101-2380 (206) 628-6600 1 RESPONSE: 2 JMM incorporates herein its Preliminary Statement and General Objections and further objects to this request on the following specific grounds: the request is overbroad, 3 overly burdensome, lacks foundation and is not reasonably tailored to the facts of this case, and seeks information and documents that are not relevant or reasonably calculated 4 to lead to the discovery of admissible evidence.

Outstanding in the divisions of work ia this plant are Tin Can Manufacture, White Lead (Dutch and "Quick* processes).

I'm talking about childhood lead poisoning

HOYT METAL PRODUCTS UNITED LEAD PRODUCTS Branch Addresses: National Lead Company, New York, Chicago, Cincinnati, Baltimore, St.

npany ldes ; With \ Pa `ted St ates Dependable White-Lead for any formula .DRY W H IT E - L E A D - D u t c h or Carter ..H.T.S.

ANACONDA LEAD PRODUCTS COMPANY NEW YORK.

9 LEAD INtAA>i*u&* Groyfcer luMnfb 430 Uxingt* AveM* NViHr.

Joseph Lead Co.

Joseph Lead Co.

tnn ikt duk sj ^QiUiam ^Qiltnii Co--ni Thera baa been an addition to the therapeutic treataant of lead absorption and intoxication , a preparation known as EDTi vhich is known as a chelating agent- this neutralizes the lead in the circulation and body tissues.

9 LEAD INtAA>i*u&* Groyfcer luMnfb 430 Uxingt* AveM* NViHr.