Each Interrogatory that inquires about plants other than the plant or plants at which plaintiff allegedly worked is overly broad, burdensome, harassing, irrelevant, and not reasonably calculated to lead to discovery of admissible evidence.

Each Interrogatory that inquires about plants other than the plant or plants at which plaintiff allegedly worked is overly broad, burdensome, harassing, irrelevant, and not reasonably calculated to lead to discovery of admissible evidence.

Each Interrogatory that inquires about plants other than the plant or plants at which the Plaintiffs allegedly worked is overly broad, burdensome, harassing, irrelevant, and not reasonably calculated to lead to discovery of admissible evidence.

Each Interrogatory that inquires about plants other than the plant or plants at which plaintiff allegedly worked is overly broad, burdensome, harassing, irrelevant, and not reasonably calculated to lead to discovery of admissible evidence.

Each Interrogatory that inquires about plants other than the plant or plants at which plaintiff allegedly worked is overly broad, burdensome, harassing, irrelevant, and not reasonably calculated to lead to discovery of admissible evidence.

Further, the definition seeks to require responses on behalf of entities at which the Plaintiffs are not alleged to have worked and, therefore, the definition and request for information concerning said entities is not relevant to the issues inquired of herein nor is the information likely to lead to the discovery of admissible evidence.

. , . 119 Liquid Red Lead . . . . . 119 Non-Corrodible Graphite Paint . . . 115 Roof and Bridge Paint............................ 121 FOB IRON GRILLE WORK Flat Black ............................................ 149 `f o r RADIATOR8, PIPING, BTC

Further, the definition seeks to require responses on behalf of entities at which the Plaintiffs are not alleged to have worked and, therefore, the definition and request for information concerning said entities is not relevant to the issues inquired of herein nor is the information likely to lead to the discovery of admissible evidence.

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Further, the definition seeks to require responses on behalf of entities at which the Plaintiffs are not alleged to have worked and, therefore, the definition and request for information concerning said entities is not relevant to the issues inquired of herein nor is the information likely to lead to the discovery of admissible evidence.

Further, the definition seeks to require responses on behalf of entities at which the Plaintiffs are not alleged to have worked and, therefore, the definition and request for information concerning said entities is not relevant to the issues inquired of herein nor is the information likely to lead to the discovery of admissible evidence.

Further, the definition seeks to require responses on behalf of entities at which the Plaintiffs are not alleged to have worked and, therefore, the definition and request for information concerning said entities is not relevant to the issues inquired of herein nor is the information likely to lead to the discovery of admissible evidence.

Defendant objects to each request as overly broad and because the request seeks information or documents not relevant to the inquiries herein nor likely to lead to the discovery of admissible evidence.

Further, the definition seeks to require responses on behalf of entities at which the Plaintiffs are not alleged to have worked and, therefore, the definition and request for information concerning said entities is not relevant to the issues inquired of herein nor is the information likely to lead to the discovery of admissible evidence.

HWBB-000761?