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.

First Resin (Modified Phenolic) Dehydrated Castor Oil Mineral Spirits Drier Lead (Lead Acetate) Lbs. 250 400 650 16 6 Yield in Gals. 25 50 100 2.25 Unit Cost Total Cost .17 per lb. .20 " 11 .09 " gal. .80 11 11 .15 11 lb. 42.50 80.00 9,00. 1.80- .90 177.25 134.20 Calculated Yield Manufacturing Loss (Approx. 5$) Actual Yield 177.25 9.25 168.00 Cost Analysis: Material Cost per Gallon .80 Labor & Overhead (mixing, cooking, thinning, filtering, labeling: & Overhead) -J2Q Complete Pkge.

Abex further objects to this request on the ground that the information it seeks otherwise lacks relevance to the issues arising in this case, and is not reasonably calculated to lead to the discovery of admissible evidence.

Abex further objects to this request on the grounds that it is compound, vague, ambiguous, overly broad as to time and scope, unduly burdensome, irrelevant to any issue in this action and not reasonably calculated to lead to the discovery of admissible evidence.

It had very little lead absorption in before the collection of these samples.

I note from your letter that an abnormal amount of lead had been reported as being present in this man's urine.

Abex further objects to this interrogatory oh the grounds that the information or materials it purports to seek lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the discovery of admissible evidence.

-PT. 3 PLANT EHERSENCIES/ALAAMS SAFETY DIRECTOR - KEY ELEMENTS PLANT MANAGER - OPERATIONS INTRO VCB SAFETY LEAD SAFETY TOXIC SUBSTANCES CONTROL ACT PUNT SAFETY GUIDELINES DuPOKT-KEN EMPLOYEE SAFETY TRAINING LIFTING - BACtSBOOL FILM HAZARD COMMUNICATION-PLANT PROGRAM SAFETY-A HATE OF MIHD-SSI1 VCM l LEAD DOSIMETRY .

Abex further objects to this interrogatory to the extent it purports to seek information or materials regarding time penods 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.

% Red-Lead "A-: .V-; ;i 2' ->!

Stop am< IW HAZARD W VCM 'i Lead Total Dust SAm2S,iT5ft.T,ION (^.

First Resin (Modified Phenolic) Dehydrated Castor Oil Mineral Spirits Drier Lead (Lead Acetate) Lbs. 250 400 650 16 6 Yield in Gals. 25 50 100 2.25 Unit Cost Total Cost .17 per lb. .20 " 11 .09 " gal. .80 11 11 .15 11 lb. 42.50 80.00 9,00. 1.80- .90 177.25 134.20 Calculated Yield Manufacturing Loss (Approx. 5$) Actual Yield 177.25 9.25 168.00 Cost Analysis: Material Cost per Gallon .80 Labor & Overhead (mixing, cooking, thinning, filtering, labeling: & Overhead) -J2Q Complete Pkge.

^'Nanes.r^PioneerrRed Lead in Oil Iw^^^^^S^'Wwysi v Red,Lead |ji Oil UAN FRANC); lgggg$igj**r ^ i715''' \: Lbs. 955 XL eld In Gals. 13.4-5 Unit Cost .0779 Lb.

August 6, 19T1 (Diet. 8/5/71) Lead Free Faint Products cra t o uni* o f wU^-jT 21, 4.971 Dic t a t e ; BV We make the following price list items and since all ore latex products they are all lead free.

Abex further objects to this interrogatory on the grounds that the information or materials it purports to seek lack relevance to the issues arising in these cases and are not calculated to lead to the discovery ofadmissible evidence.