It is overly broad, unduly burdensome, ambiguous, and lacks the requisite specificity and is unlikely 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.

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.

These samples were analyzed for lead, cadmium, zinc and manganese by atomic absorption spectrophotometry.

-5- Defendant further objects to this request for the reason that it seeks information which is irrelevant, immaterial and not reasonably calculated to lead to the discovery ofadmissible evidence related to the Defendant's jurisdictional contacts, ifany, w

Al, Si, Cu - traces The Pb, Cl, and Br are present by virtue of the tetra-ethyl lead together with the ethylene chloride and bromide added to scavenge the lead.

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

Defendant objects to this request as vague, overly broad, unduly burdensome, unlimited in scope and time, and seeks information not relevant or reasonably calculated to lead to the discovery of relevant or admissible evidence.

It sh ould be realized th at th e n ature and sym ptom s o f organic lead poison in g are quite differen t fr om in organ ic lead poison in g or plum bism .

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

Tltaniwn Oxldo 1403-X Titaniva Dioxide ' M17 Alisarlne Lilae Ia Ia (Ueed in R>: 239) AV4 Vtw *vu<n / (T^d IfnTSrBOTl-------------* ICO" Print Pr1jvlr* Bed Lead ''Containing not lens then ' 90* True Il-d Lead* 3POC Tr>m OrId* ftl-llooau* pass (For "rog-n Goods (Kly) >) 11*09.

Dow R&S162260 8 further objects because the documents sought in this request are neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.

To the extent that these interrogatories seek information regarding alleged potential health risks to individuals who worked at plants where Abex's asbestos-containing automotive friction products were manufactured, Abex objects on the grounds that such information is not relevant to this lawsuit and is not reasonably calculated to lead to the discovery of admissible evidence.

DETROIT W3TTE LEAD WORKS.

The two new reviews recently submitted by Professor Drinker on: a) Oil Mists b) Lead Compounds in Cutting Oils He recommended: ' 1.