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.
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May I say, in closing, what a pleasure it has been to read your most comprehensive chapter, in Tices Medicine, on lead poisoning.
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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.
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&peci1ic u-ra-v1ty i%* tb/Liter - 55^-5794 - 6 5 m l, - 1.017 - 0.05 Bt00 Analysis "number drams fey;, P b / l O O wrasis - 55**5755 Dith.lr.one - 11*9 - 0 .Oh Dithiaone } 16 .7 0 *0/t5 The levels of lead con cen tration in both the urine and blood ar e well within n orm al lim it s, th ereby dem on stratin g that th ere h as been no abn orm al or unusual exposu re to, and absorption of, lead recen tly.
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ANSWER TO INTERROGATORY NO. 33: Abex objects to this interrogatory on the grounds that it is overly broad, burdensome, lacks relevance to this case and is not reasonably calculated to lead to the discovery of admissible evidence. 34.
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co2i vinTiais* a&ECiiacruaiiB bvtus mmrs ILLINOIS PAINT WORKS GRADS SPECHriCATIONS Aim COST ANALYSIS QUALITY MIXED LONGLIFE HOUSE PAINT EXTERIOR HOUSE PAINT WHITE 1243 2nd QUALITY PIGMENT 6686 Lead Sulphate 35$ Leaded Zinc Oxide Asbestine VEHICLE 34& Raw Linseed Oil Driers Mineral Spirits Calculated Yield Mfg.
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In the matter of finding someone to make lead analyses, I have some question as to whether this will be either necessary or advisable.
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ANSWER TO INTERROGATORY NO. 41: Abex objects to this interrogatory on the grounds that it is overly broad, burdensome, lacks relevance to this case and is not reasonably calculated to lead to the discovery of admissible evidence. 42.
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CHICLE DEVELOPMENT COMPANY 500 FIFTH AVBNDB New Yor k March12th 19S6 W Messrs The Chicle Boreiopaent Co* 2ewYork* Dear yr Yates, * ri of the 29th and I shall January be only to hand* thI&wtatsraseoerrjy>3to too pleased to dowhat I see can tb, your letter ^glipving trouble inclined to put a lot of the so often used by the Chinese^ yet tested this but will do 8 darft Xshould be cap sulphuric sold in# althoug Xhave not of lead in sty guth are used in any not explain the traces no lead containing materials end 1*11 test t # it my already be in the aoetio coagulants are carried about in common lity# and the acide are alwey# imparted The Chinese always smear the inside of their to stop the gatta fromsticking to the boxes or it in cast iron "qualles" straightway with a little Xattach answers to Refining process questionnaire* The field experiments will bo done as soon as possible bstuotpXthme. lseeanddintrgouthbilse aqhueiacdk#ly#wiathn#d weviethryawsilsihtttlheateyxopuenwseilalsbpeoasbsilbeleto* Yours very sincerely C*J*i3inisor* 00Co3 i.)
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Apropos of lead hazards, as I recall it, some time ago both du Pont and Ethyl management were going to receive quarterly reports from you as to the hygienic conditions at both plants.
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GalsT ,< Pigment 69^ 1 2800 185 2850 850 JJJT vkltle Cobalt Blue 59.56 Zinc Oxide 3.94 .soil 15% Leaded Zinc Oxide i 79.52 OWS' Titanox B ' 35.80 Asbestine I r-TmfpJ- 07# 0675# 06# 01# 196.00 12.488 171.000 8.50 3l 3246.1 240 240 5019 80 95 139 32 418.85'. iH Mechanically Refined Linseed 30 :-035 Blown Linseed , 50 ; 500 Oil-Treated Linseed '218.24''' ^ Lead Paste (4065# Carb.Leaid v.. (12'3'Gal.Mech.
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$ the remissive amount of tetraethyl lead in gasoline.
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GM also objects to this request because it is vague, overly broad, unduly burdensome, and unlikely to lead to admissible evidence.
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-PT.3 PLANT EMER6ENCIES/ALARHS SAFETY DIRECTOR KEY ELEMENTS PLANT MANAGER - OPERATIONS INTRO * VCft SAFETY LEAD SAFETY TOIIC SUBSTANCES CONTROL ACT PUNT SAFETY EUIOaiNES OuPONT-NEN EMPLOYEE SAFETY TRAININ6 UPTIME - BACKSHOQL FILM HATARO COMMUNICATION-PLANT PROSRAM SAFETY-A STATE OF KIND-SSII VCH l LEAO DOSIMETRY FIRS!
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ANSWER TO INTERROGATORY NO. 39: Abex objects to this interrogatory on the grounds that it is overly broad, burdensome, lacks relevance to this case and is not reasonably calculated to lead to the discovery of admissible evidence.
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