GM also objects to this interrogatory because it is overly broad, burdensome, oppressive and not likely to lead to admissible evidence.

Abex 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 Abex also 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.

ANSWER TO INTERROGATORY NO. 76: 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.

not reasonably calculated to lead to the discovery of admissible evidence.

\ In the Receiving Department for the past 1|. years* General medical history and physical examination reveals no evidence of disease, occupational or otherwise, on this man* Laboratory data show only that the amount of lead in the urine and blood are somewhat increased above the normal Conclusions and Recommendations This man Is In excellent physical and mental health and the above mentioned lead increase is not sufficient to produce disease In this man.

Shattuck; My office has noted that the gift from the Lead Industries Association for the use of Dr* Aub and Dr* Fairhall, of which $3,000. has been received, has been put under Idle School of Public Health funds.

GM objects to this interrogatory because it is overly broad, unduly burdensome, 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 White Lead Carbonate In Oil-in Pasto Form COLOR White NUMBER Ull QUALITY First POUNDS YIELD IN GALLON UNIT COST TOTAL COST PIGMENT 90$ Basic Lead Carbonate VEHICLE 10# Linseed Oil 22U.C6 Sh.98 .0675 lb. 19.68 .11 2.75 CALCULATED YIELD MANUFACTURING LOSS- 3.I4I4# ACTUAL YIELD 21&.01+ 7.25 .25 7- 22.Uj COST ANALYSIS: Material cost per gal Ion <w-pound Direct labor cost per gallon or-peundFactor; overhead per gallon or-pattodBulk cost per gallon or-powd Complete package cost per gal Ion -or-poond-(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 OPA (C) By company owned or controlled outlet to retail customer (D) To an independent retailer (Dealer) (E) To other (Specify) Non-dnlr fr. manufacturer 1B001078 5.2C 3.u 6.

Granted th at massive exposure to lead may in rare instan ces be causative of optic n eu r it is, t h is alleged contention r elat ive to lead pain ts st r ik es me as quite u tt er ly screwy.

Abex 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 reasonably calculated to lead to the discovery of admissible evidence.

THE MECHANIC DOING THE WORK WILL CONTACT THE PERTRI LEAD OPERATOR PRIOR THE REMOVAL OR INSTALLATION OF THE SRV. _______ 2.

Heaerre for Preigfat and Safining Manufactured Froducta: Lead Froducta Zinc Oxide - Finished.

1 lead to mesothelioma?

An investigation was made of airborne lead, airborne asbestos, methyl ethyl ketone and noise exposures.

Abex further objects to this interrogatory on the ground that it purports to shift the burden of establishing product identification from plaintiffs to Abex Abex objects to this interrogatory to the extent it purports to seek information or materials regarding tune 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 Abex also objects to this interrogatory on the grounds that the information or matenals 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 further 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 Nos 14 and 19.