NATIONAL LEAD C0 1IH" New Yorfc, 11?

renders the interrogatories as a whole, irrelevant to the subject matter of this action individually, and not reasonably calculated to lead to the discovery of admissible evidence.

PP POOT S-YBAR LEAD STUDY.

-PT.3 PLANT EKERSENCIES/ALARMS SAFETY DIRECTOR - KEY ELEMENTS PLANT KAHABER - OPERATIONS INTRO VCH SAFETY LEAD SAFETY TOXIC SUBSTANCES CONTROL ACT PLANT SAFETY GUIDELINES QuPGKT-NEM EMPLOYEE SAFETY TRAIXIKS LIFTING - SACKSHOOL FUJI HAZARD COMMUNICATION-PLANT PROGRAM SAFETY-ft STATE OF KIND-SSII VCH k LEAD DOSIMETRY FIRST AIO ORIENTATION SECURITY PICTURES 'SAFETY EDUIPKENT ISSUE SCOn AIR PAK FRESH AIR/3H AIR HAT FORK LIFT - CLASSROOM FORK LIFT - FIELD l LICENSE EOUIPKEKT ENTRY - FILM PLANT ENTRY k LOCKOUT PROCEDURE LOOK BEFORE YOU REACH' -SLIDE SHQK DON'T PUSH YOUR LUCK-FILM SAFETY LOCK ISSUE MAKE MEETINGS REAM SQKETHIKS-SSI2 THE CONVINCES-SLIDE SKQN LINE BREAKING-FILM PLANT INTRODUCTION SHOY CONTRACTOR VCH HEALTH CONTRACTOR LEAD HEALTH PLANT SAFETY GUIDEIHES CONTRACTOR HAZARD' COMMUNICATION BA0GE-MAKE/LQ6/UP0ATE GUARD LIST

> Contains Lead Compounds.

Abex further objects to this interrogatory on the grounds that it is premature, overly broad, oppressive, harassing and unduly burdensome in that, to date, plaintiffs have failed to proffer any evidence showing the requisite nexus between plaintiffs and/or plaintiffs' decedents and any Abex product Abex objects to this interrogatory to the extent it purports to seek information or matenals regarding time periods and products that are not at issue m these cases, on the grounds that such information or matenals lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence To the extent it purports to seek information or materials regarding the working conditions of Abex employees, this interrogatory is also objected to on the grounds that such information or materials lack relevance to the issues ansing in these cases and are not reasonably calculated to lead to the discovery of admissible evidence Abex further objects to this interrogatory on the grounds that the information or matenals it purports to seek lack relevance to the issues ansing in these cases and are not calculated to lead to the discovery of admissible evidence Abex objects to this interrogatory on the ground that it assumes the truth of -82-

Lead Industries Association, Inc.

-PT.3 PLANT EKERSENCIES/ALAAHS SAFar DIRECTOR - KEY ELEKENTS PUNT MANAGER - OPERATIONS INTRO VCSSAFCTT LEAD SAFETY MIC SUBSTANCES CONTROL ACT PLANT SAFETY GUIDELINES OuPGKT-NEK EMPLOYEE SAFETY TRAINING LIFTING - BACtSHQQl FILM HAZARD COMMUNICATION-PLANT PROGRAM SAFETY-A STATE OF KINMSti VOU LEAD DOSIMETRY FIRST AIO ORIENTATION SECURITY PICTURES 'SAFETY EflUIPMEXT ISSUE SCOTT AIR PAK FRESH AIR/3M AIR HAT FORK LIFT - CLASSROOM FORK LIFT - FIELD l LICENSE ECUIPAENI ENTRY - FILM PLANT ENTRY k LOCKOUT PROCEDURE LOOK BEFORE YOU REACH' -SLIDE SHON DON'T PUSH YOUR LUCK-flLN SAFETY LCCX ISSUE MAKE KETIXSS KEAN SQKE1HIKG-SSt2 IKE aWYlKCER-SUK SHOT UNE 8REAKlK6-ftUl I I $/ll tm PUNT INTRODUCTION SKON CONTRACTOR YCK HEALTH CONTRACTOR LEAD HEALTH PUNT SAFar GUIDELINES CONTRACTOR HAZARD" COKKJXICATIQN BA06E-KAKE/IQG/UPDATE GUARD LIST 1 f \

a* cent* net per pound BED LEAD (P*$T). ffrourrf In off. for Dtombing and painting wes In t poaad cant...................................... . rt Cent* act per pound 0 WHITE LEAD (PASTE).

Accidental poisonings from carbon monoxide gas occur almost daily; and children have contracted lead poisoning by sucking lead-painted toys.

If the trees are heavy vith spray, a considerable amount of dust vill result from the picking operations, and individuals may absorb considerable Quantities of both lead and arsenic,(provided, of course, lead; arsenate vas used as the spray).

. ^ / <* LEAD INDUSTRIES ASSOCIATION *j NEW YOHK 17, N.

The consolidation includes only domestic subsidiaries in which National Lead Company owns all of the outstanding capital stock.

Daly Chicago Plant ' Control of Lead Levels 8/3/78 F.

Lead prices now at 21C/lb. with some expectation that it may drop lower.