t ^,Cv 1 LEADED ZINC OXIDE j ] I i --' /, I.

Within these groups two lead levels are considered, 0.15 gPb/1 and zero, for three refinery types; crude input varies between 100% North Sea type and 100% Middle East.

.-- fhc Cute* Scbcac* Tbe Faint ami (be Pstruer. } l NATIONAL LEAD COMPANY 1.

White-had; vfaA wM aot fao Afeach at TW white-lead which pane* Aroagfc the bohlag doth tf pumped ate brpe acttlng tab*; There it eetUee to the bottom ae wet pulp, the wipiut nto beng thawu off hoo the top. 4 t White-Lead NLl 001680 i. r r, f^L I 001681 1 -ill VkitwL'a* Ofixmrr i by the tv* m a .

Fumes of lead, lead alloys, cadmium and beryllium arc extremely toxic and complete respir atory protection must he provided for the operator and other workers in the fume area.

.-- fhc Cute* Scbcac* Tbe Faint ami (be Pstruer. } l NATIONAL LEAD COMPANY 1.

NMBB-000761?

It is anticipated that further discovery, independent investigation, legal research, and analysis will supply additional facts, add meaning to the known facts, as well as establish entirely new factual conclusions and legal contentions, all of which may lead to additions to, changes in, and variations from the responses herein set forth.

NMBB-000761?

As a result, such general discovery requests are overly broad, unduly burdensome and not reasonably calculated to lead the discovery of admissible evidence against Rockbestos. 2.

--stand the wear._-............. 31 White Lead, Old Dutch Process..................

CAUSE NO. 01-00887-B TIMOTHY CLAUD MCMURROUGH, ET AL VS.

Defendant further objects to the definition of these terms as calling for the production of material or information which is not 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 not relevant nor reasonably calculated to lead to the discovery of admissible evidence.

Lead Operator Duties 2.