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.

Job Code Time Start___________________________ Stop _____ AM{ JPMtfT) -JlllL____ AM(T)PM< J Airflow HAZARD VCM Lead Total Dust ^fcllSBSPJWffl0N U-^7 -ppM --Micrograms/M --Milligrams/M^ Sample Time PEL: ' --Micrograms/M^ Analyst^ Analvlis Date^//' // Hazard: VCM ( ) Lead ( ) Dust ( } ( } N9 001431 1.

2: PRODUCTS COiTAlNING OVER C.St LEAD L\ uKIED IL" Viscosity: t Plash Point: Over ICC SU3, 21 Ceut-stokes.

I' RADE NAMEI ATEGORY: OLORr UMBER: UALITY: KILBOURN EXTERIOR WHITE 687 THIRD PASTE WHITE WHITE PASTE T3i;-- GAT57 igaent 78# - 34 75 78 416 350 * 150 'ehlcle .72 2.03 3.39 11.86 14.7 9 Low Zinc Oxide #55 Barytes Lead Paste (63# Lead Carb. (15# Mechanically Ref.Linseed Lithopone XX Metronite Dicalite L Grade 22# .27.875 95 12 50 16.50 -10 1.5 7.75 Mechanically Refined Linseed Acid Refined Linseed Oil Cobalt Drier Oleum 1367.875 77.45 1.54 - 2# Mfg.

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 matenals 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 matenals 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 established or matters not in evidence Subject to and without waiving these objections, and insofar as Abex understands this interrogatory, see Answer to Interrogatory No 19 -41-

The failure of plaintiff to limit these interrogatories to information related to Abex's alleged . liability in this case renders the interrogatories as a whole, irrelevant to the subject matter of this action individually, and not reasonably calculated to lead to the discovery of admissible evidence.

lacks relevance, and is not reasonably calculated to lead to the discovery of admissible evidence.

Abex further objects to this interrogatory 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 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 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.

As you know, this laboratory has just completed a three-year study of the problem Of lead poisoning, and a book covering the entire subject is now in the process of publication and should appear early in the new year.

PROPOSED REPORT FORM FOR FIELD TEST OF DECALCOMANIA LEAD WARNING SIGNS ' Name of station operator Address of station Mr.

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.

-:les . . 0 24 0 M________ .A Please pay this amount a $65.00 inr M $65.00 chocks shall be riuui* payable to: LEAD INDUSTRIES ASSOCIATION, INC

Objection is also made to the extent these interrogatories assume the truth of matters not established, and on the grounds that they seek information which is not relevant to the subject matter of this lawsuit and not reasonably calculated to lead to the discovery of admissible evidence.