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.

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 penods and products that are not at issue m these cases, on the ground 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 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. -162-

Page 3872 1 instruction, and the reason we would do so is because 2 of the facts of this case. 3 By its very nature friction products are an 4 expendable or renewable product, and I think just the 5 way the continuing duty to warn instruction is phrased 6 and as given, it leads to some kind of confusion 7 because -- especially with respect to the facts in the 8 Wood case where the vehicles were so much -- so old by 9 the time Mr.

Cryptone BA-19 Lead Titannto Lbe. 420 100 Yield In Gals. 12 1.65 "'iTUst> Unit Cost TOTAL COST 6.10 C'.vt. 11.25 " {25.62 11.25 VEHICLE: 59.5?

Sample Number ALHV-1 Sample Volume 3 (cubic meters, hi ) 89.0 ALHV-2 125.7 Table 2 Allied Brake Shop Air Sample Results Trace Metal Analysis Sample Location Brake Service Area General Shop Area Pb 4.04 1.27 3 Trace Metal Concentration yg/m Zn Cu Fe Mn 0.74 0.27 18.00 0.21 2.07 0.17 12.72 0.18 Cr 0.11 0.07 Limit of Detection (yg/sample) Lead Zinc Copper Iron Manganese Chromium 4 5 2 4 2 3 OSHA Standard :(yg/m Lead Zinc oxide fume Copper dust Iron oxide fume Manganese Chromium metal 50 5,000 1,000 10,000 5,000 1,000 (TWA) (TWA) (TWA) (TWA) (ceiling) (TWA) NIOSH Recommended Standard (yg/m ) 100 (TWA) 5000 (TWA) None None None None

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.

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.

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 penods and products that are not at issue m these cases, on the ground 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 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. -162-

Lead 4 C o lo r Worka Hoporc o f R aceiota______________ Erprc.f f / ' /?

HAZARD VCM 8AmssBBawsBfisoM Jsfrf-ma Sample Time Lead --Micrograms/M^ PEL: --Micrograms/M^ Total Dust -Milligraim/M^ Analyscrl -*^y ABD00325287 Hazard: VCM ( ) Lead ( ) Dust ( ) V I cfme'to work at ijX'-- AM PM { ) TM 2.1 left work at ( Q&o AM ( ) Vfilin'3.1 did the regular work of a (enter Job Class) 4.1 used a respirator during the following jobs tcheck one) None Oust Mask N Work?

V^ jV*' ; We are enclosln herewith analytical ` - .report on the urine of Mr* 219 182 In view of the absence of any lead In the specimen.

General Mechanic 2,4* ppm, VCM General Mechanic 2.2* ppm, VCM Instrument Technician 9.3** ppm, VCM Rx Operator 1.4* ppm, VCM Rx Operator 145.6* ppm, VCM Line Compounder 39.8* micrograms Lead/m^ Respiratory protection was worn, Respiratory protection was not worn.

ANSWER: Abex objects to this interrogatory on the grounds that said Interrogatory is overbroad and 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 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 further 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.