PLAINTIFF'S EXHIBIT AL-I273 >5 Current Report Lead LONG-RANGE OPTIONS FOR CONTROLLING LEAD CAN BE CONSIDERED IN EVALUATING COMPLIANCE Citations for failure to meet the deadline for preparing compliance plans under the Occupational Safety and Health Administration's lead standard will not be issued to employ ers in the primary and secondary smelting and battery manufacturing industries if the employer has initiated a study of long-range control options and has met other re quirements, according to a draft field directive by OSHA.

Gypsum objects to these Interrogatories to the extent they ask for "identification" of voluminous documents on the ground that they are overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence.

k IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OKLAHOMA IN RE: ASBESTOS PERSONAL INJURY CASES ) ) ) No.

The bases for such objections are that any responses would be irrelevant to the subject matter of the pending litigation, would not be reasonably calculated to lead to the discovery of admissible evidence, and would be burdensome and oppressive.

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Our laboratories are con Arco Gloss Primer--A pig stantly engaged in the improve mented primer designed to take ment of present methods and the place of lead and oil for prim materials.

In summary, Westinghouse opposes only a type and volume of discovery which would impose an unreasonable burden on Westinghouse because it is not tailored in any way to deal with a corporation such as Westinghouse, or reasonably designed to lead to the discovery of admissible evidence concerning the products the plaintiffs reasonably believe to have caused them harm.

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In summary, Westinghouse opposes only a type and volume of discovery which would impose an unreasonable burden on Westinghouse because it is not tailored in any way to deal with a corporation such as Westinghouse, or reasonably designed to lead to the discovery of admissible evidence concerning the products the plaintiffs reasonably believe to have caused them harm.

ANSWER: Crane Co. objects to this Interrogatory because it seeks information that is not relevant to this action, and because it is overly broad and it is not reasonably calculated to lead to the discovery of admissible evidence.

Alas Sterert of the National Uad Ccnpew, f a session m the Ned lead Technical Cootlttee was held on Pa/ k lit the Association offices to reconsider resolutions previously dra*a ep on the labeling of red lead and paints containing red lead.

Further 3 discovery, independent investigation, legal research and analysis may supply additional facts, 4 add meaning to known facts, and establish new factual conclusions and legal contentions, all of 5 which may lead to additions, changes and or variations from the present response.

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In summary, Westinghouse opposes only a type and volume of discovery which would impose an unreasonable burden on Westinghouse because it is not tailored in any way to deal with a corporation such as Westinghouse, or reasonably designed to lead to the discovery of admissible evidence concerning the products the plaintiffs reasonably believe to have caused them harm.

This is then insulated in a continuous length and when out in the middle of each lead wire a complete heating unit with leads, ready for connections, results.