The chief sources of lead fumes, according to union authori ties, are in bolting, riveting end cutting of steel structures which were coated with lead paints, the first in

ANSWER asbestosis lung cancer mesothelioma ~ Defendant objects to this Interrogatory because it is overly broad, vague, not limited to the time periods and corresponding worksites relevant in this case and, therefore, seeks information irrelevant and not reasonably calculated to lead to the discovery of admissible evidence.

The chief sources of lead fumes, according to union authori ties, are in bolting, riveting end cutting of steel structures which were coated with lead paints, the first involving contact p

Appleton Electric Company objects to this interrogatory as it is overbroad, assumes facts not in evidence and seeks information which is not relevant nor reasonably calculated to lead to the discovery of admissible evidence.

INTERROGATORY NO. 2: As to each of the following, please state the first year you first became aware, what you learned, and how Defendant learned that humans who inhale asbestos fibers can contract a. asbestosis b. lung cancer c. mesothelioma ANSWER: Defendant objects to this Interrogatory because it is overly broad, vague, not limited to the time periods and corresponding worksites relevant in this case and, therefore, seeks information irrelevant and not reasonably calculated to lead to the discovery of admissible evidence.

Bull., 23, 178 (May 1944) 781 Study Lead Poisoning Hazards in Structural Steel Work.

ANSWER asbestosis lung cancer mesothelioma Defendant objects to this Interrogatory because it is overly broad, vague, not limited to the time periods and corresponding worksites relevant in this case and, therefore, seeks information irrelevant and not reasonably calculated to lead to the discovery of admissible evidence.

RESPONSE; Appleton Electric Company objects to this interrogatory as it is overbroad, assumes facts not in evidence and seeks information which is not relevant nor reasonably calculated to lead to the discovery of admissible evidence.

This combination can be competitive in today's lead market.

ANSWER asbestosis lung cancer mesothelioma ~ Defendant objects to this Interrogatory because it is overly broad, vague, not limited to the time periods and corresponding worksites relevant in this case and, therefore, seeks information irrelevant and not reasonably calculated to lead to the discovery of admissible evidence.

Lead Operator Duties 2.

Low prices for lead and sil ver also affected operations at our East Helena, Montana, lead smelter and our Omaha, Nebraska, refinery.

PLAINTIFF'S EXHIBIT ASA-411 ,97 '935 />v<fsqf {OSH.)

(h) Abex objects to this interrogatory on the grounds it is vague, ambiguous and is not calculated to lead to the discovery of admissible evidence.

ISCF-ALLF-01045 SC-ALL-03905 NATIONAL SAFETY NEWS PsbHsfctd Monthly by tfao National Safety Cornell FEBRUARY, 1948 VoL 57.