n )" ; L.

r V n [ r-.

F' wpdocs 11592'discovery INREresponsecoplainhffimerrogs&rfp.OOl.wpd -4- ANSWER TO INTERROGATORY NO. 1: Defendant objects to this Interrogatory as overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of relevant, admissible evidence.

r V n [ r-. f ; L--'* t--^ V*d^ e^i ^ ri i' iu uUuU l-ju-J nI r?

n )" ; L.

Fluors investment in lead is conducted through The Doe Run Company, which produces approximately 50 percent of all U.S. primary lead metal, and operates one of the worlds environmentally cleanest secondary lead recycling plants.

s alleged liability in these cases renders Plaintiffs' Discovery as a whole irrelevant to the subject matter of these actions, and not reasonably calculated to lead to the discovery of admissible evidence. 5.

r V n [ r-. f E u-X e^i ^ ri ; i L> Li uUuU i-jl-J nI r?

Laboratory Supervisor/Lead VAB.000120964b S flat- fO-/C'fO ________ Product^___________ __ Trailer Number Customer .

n ) " v ; L.

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.

Arsenate of Lead.

Castleman File: American Petroleum Institute w/c = with cover letter or memo If DATE = 0, undated CD-ROM Document #:API iQQ DATE / published article from trade journal published advertisements newspaper article published government report government inspection results unpublished or internal report unpublished presentation from conference letter memorandum industry warning labels industry sales literature industry recommended practices meeting minutes (with attachments) membership list BC notes ANY WAY YOU MEASURE" MAY 19 1955 '.kSITV OF CALIFOR c ..

Therefore, the response of NSRC to such interrogatories could not lead to the discovery of admissible evidence.

Therefore, the response ofNSRC to such interrogatories could not lead to the discovery of admissible evidence.