Airflow HAZARD 'VCM Lead Antimony Total Dust Noise SAMPLE CONCENTRATION (Time Weighted Average) /Z.

Abex further objects to this interrogatory to the extent it purports to seek information or materials regarding time periods and products that are not at issue in these cases, on the grounds that such information or materials lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence.

Lead in Oil A.

Abex also objects to this interrogatory on the ground that it purports to shift the burden of establishing product identification from plaintiffs to Abex Abex further objects to this interrogatory to the extent it purports to seek information or materials regarding time periods and products that are not at issue in these cases, on the grounds that such information or materials lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence Abex objects to this interrogatory on the grounds that the information or materials it purports to seek otherwise lack relevance to the issues arising m these cases and are not reasonably calculated to lead to the discovery of admissible evidence Abex also objects to this interrogatory on the ground that it assumes the truth of matters not estabhshed or matters not m evidence Subject to and without waiving these objections, insofar as Abex understands this interrogatory, and upon information and belief, some Abex products may have undergone changes after sale by Abex and prior to reaching the ultimate end-user.

To the extent it purports to seek information or materials regarding the working conditions of Abex employees, this request is objected to on the grounds that such information or materials lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the discovery of admissible evidence.

____ ~~ J ______' i ; "` \ PLANT INTRODUCTION SKGK CONIRACTQR VCK HEALTH CONTRACTOR LEAD HEALTH PLANT SAFETY GUIDELINES CONTRACTOR HAZARO COWaCATION BADGE-KAKE/LOG/UPDATE GUARD LIST I I

ANSWER TO INTERROGATORY NO. 53: Abex objects to this interrogatory on the grounds that it is over broad, unduly burdensome, compound, vague and ambiguous and calls for speculation Abex also objects to this interrogatory on the grounds that the information or matenals it purports to seek lack relevance to the issues arising in these cases and are not calculated to lead to the discovery of admissible evidence.

., rum Trade Mu ms Cate(0i7i Colon Nunbers Quelityi Copent Prepared Paint #40 Outaide White Exterior Houle Paint Wdte 301-756 Pint Piament 635 TlPure 35* leaded Zinc Caddo .

I wonder if you have' any experience on methods to analyze organic and inorganic lead separately in biological material such as blood and urine.

Being a pure white lead paint is the first advantage of Eagle RTU. ..

ANSWER TO INTERROGATORY NO. 69: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous and calls for speculation Abex also objects to this interrogatory on the ground that it purports to shift the burden of establishing causation from plaintiffs to Abex Abex further objects to this interrogatory to the extent it purports to seek information or materials regarding time periods and products that are not at issue in these cases, on the ground that such information or materials lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence Abex objects to this interrogatory on the grounds that the information or materials it purports to seek otherwise lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the discovery of admissible evidence Abex also objects to this interrogatory on the grounds that it assumes the truth of matters not established or matters not m evidence -159-

As the roll cam rotates, it imparts axial motion to the lead screw and nut.

Abex objects to this interrogatory on the grounds that it lacks relevance to this case and is not reasonably calculated to lead to the discovery of admissible evidence.

> A ITEM NO. 25 TRADE NAME PURE COLOR IN OIL;.FLAKE WHITE CATEGORY Whito Lead Carbonate In Oil-in Pasto Form COLOR V/hite NUMBER 4ll QUALITY F^st POUNDS YIELD IN GALLON UNIT COST TOTAL COST PIGMENT 9<# Basic Lead Carbonate VEHICLE lOjg Linseed Oil 224.86 24*98 .0075 lb. .11 " . 19.68 ' 2.75 CALCULATED YIELD MANUFACTURING LOSS- 3-44# ACTUAL YIELD 249.04 7.25 .25 7- 22.1;; COST ANALYSIS: Material cost per gal Ion -pound Direct labor cost per gallon or-peundFactory overhead per gallon or-pauodBulk cost per gallon or-powd Complete package cost per gal Ion -er-peond-(container plus filling expense) Factory cost in package per gallon or-peund- SALES PRICES (A) To a company owned or controlled outlet (B) To an independent wholesaler (C) By company owned or controlled outlet to retail customer (D) To an independent retailer (Dealer) (E) To other (Specify) ?

Remember: eight out of every ten paint-, evs are using Dutch Boy White Lead r ,, . and no one knows paint like a.painter.