It seeks matters that are not relevant to the subject matter of this lawsuit or reasonably calculated to lead to the discovery of

The industrial hygienists will oxamine the health hazards in the synthetic rubber industry, radius, sol vents, toxicology of TNT, possibilities of excessive silica dust hazard fro* the extensive quartz crystal Industry, techniques of air sampling in specific refer ence to -tbs collection of cutting oil mists and of lead fines, and hazards of exposure to oadmlw* The industrial nurses will consider postwar planning for nurses and medical services in industry.

It seeks matters that are not relevant to the subject matter of this lawsuit or reasonably calculated to lead to the discovery of admissible evidence; and 2.

The lighter shades are lead sul fo chromates, containing co-precipitated lead sulfate; the medium shades are normal lead chromate, while the oranges are basic lead chromates.

The lighter shades are lead sul fo chromates, containing co-precipitated lead sulfate; the medium shades are normal lead chromate, while the oranges are basic lead chromates.

RESPONSE: DuPont objects lo this Request for Admission on the ground that it is deliberately incomplete and calculated to lead to a false conclusion.

The net effect of these two transactions is shown below: Capital stock of International Smelting and Refining Company Issued to Anaaonda Copper Mining Company - 36,500 shares - par value $75*00 each $ Assets sold to AnwMOda Copper Mining Company: Capital stock of: Copper Canyon Mining Company $ 8,600.00 Mountain City Copper Company 996,987.93 National Tunnel & Mines Company 915,693.92 North Lily Mining Company 66,527.78 Park-Utah Consolidated Mines Company 441,157.50 Prince Consolidated Mining Company 47,132.86 Notes and accrued Interest of: Notes Interest Total National Tunnel & Mines Company $ 1,950,000.00 2,537.67 1,952,537.67 Snyder Mines, Incorporated 141,040.41 5,455.16 146,495.57 Tooele Valley Rail way Company ... 103,136.57 581.39 ___ 103,717.96 $ 2,194,176.98 8,574.22 Leases and Interest on expenditures: Expenditures Interest Total Copper Canyon lease $ 1,280,518.22 Gulld-Adams lease 1,288,852.12 Victoria lease 996,830.49 $ 2,866,200.83 201,211.02 1,481,729.24 82,585.52 1,371,437.64 14,168.90 ___ 310,999-39 297,965-44 2,737,500.00 2,476,099-99 2,202,751-20 3.164,166.27 Indebtedness to Anaconda Copper Mining Company repaid: Principal aseunt Interest Total Note dated June 27,1944 $2,500,000.00 Note dated June 27.1944 8.000.000.00 $10,500,000.00 13,581.73 2,513,581.73 45,157-97 8,045.157-97 58,739.70 Net amount credited to International Smelting and Refining Company 10.558,739.70 21,777-76 fflPERATIQNS 4 Operations of International Smelting and Refining Company for the past three years compare as follows: Year 1943 Year 1944 Year 1945 Gross sales and earnings $ 22,046,552-29 21,918,993-90 19,587,706.70 Net profit on plant operations Income (loss*) from sundry Investments - page 5 Reimbursement of Interest on lease expenditures $ 764,377.88 67,745.23* Interest paid to Anaconda Copper Mining Company on debentures and notes Provision for Federal Income taxes - estimated Provision for contingencies 696,632.65 596,875.00 30,000.00 297,642.94 924,517.94 Net Income (Loss*) $ 227,885-29* 412,217.10 110,605.27* 301,611.83 341,442.49 26,279.28 297,965.44 665.687.21 395,912.44 56,500.69 . 103,296.37 395,912-44 94,300.61* 169,799.06 505,888.15 Net profit on operations of the various plants and departments of the company and income from sundry Investments for the past three years together vith the respective investment therein at December 31, 19^5 are shown in the following summary: Net Profit (Loss*) on plant operations Year 19^3 Year 1944 Year 19^5 Tooele plant $ 394,775-34* Miami plant 133,925-85 Lead refinery 32,969-95 Zinc oxide department 90,618.19* White lead department 16,823.58* Raritan refinery 1,216,453.14 Raritan electro-sheet department 34,409.58* Not allocated (details page 42) 3g.344.37* 344,208.98* 147,172.64 36,223.72 1,890-97* 21,701.99* 729,523.18 21,545-80* 111,354.70* 439,979.09* 11,911.49 40,358.34 73,431.83 19,265-33' 831,663.17 15.457.07' 141,420.85 Investment at December 31, 12i5 4,319,552.69 1,213,288.11 741.319.56 864,975-51 445,099.24 6,394,539.75 286,056.6c 476.944.56 Net profit on plant operations - as above $ 764,377-88 412,217.10 341,442.49 14,741,778.08 * Details of the above figures for 1945 are shown on the Balance 3heet and Income Account by departments on pages 14 and 15 respectively.

All reels with leaded cables (30" flange and larger) to be wood lagged.

To the extent the request is intended to encompass all areas of Defendant's premises, including those where Plaintiff did not work, the request is overly broad and calls for information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.

Information relating to CSR activities prior to 1948 or after 1966 is irrelevant and not calculated to lead to the discovery of admissible evidence.

To the extent the request is intended to encompass all areas of Defendant's premises, including those where Plaintiff did not work, the request is overly broad 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 neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.

The industrial hygienists 0, wUl oxamine the health hazards in the synthetic rubber industry, radivm, sol vents, toadoology of TNT, possibilities of excessive silica dust hazard from the extensive quartz crystal industry, techniques of air sampling in specific refer ence to the collection of cutting oil mists and of lead fimies, and hazards of exposure to oadmim.

Plaintiffs definition is not limited to the "plant(s)" at issues in this lawsuit and is, therefore, not calculated to lead to the discovery of admissible evidence.

Plaintiffs definition is not limited to the "plant(s)" at issues in this lawsuit and is, therefore, not calculated to lead to the discovery of admissible evidence.