(a) Identify the product(s) which was used in the survey, (b) Identify any and-all person(s), firm(s) or entity(ies) conducting or participating in the conducting of said survey; (c) State the date(s) of said survey; (d) Describe the methodology, results and conclusions of said survey; (e) Identify any and all documents referring to, relating to, or reflecting said survey or the results and conclusions thereof; and, (f) Identify any and all persons to whom such document may have been sent ANSWER TO INTERROGATORY NO. 55: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous and calls for speculation ' Abex also objects to this interrogatory to the extent it purports to seek information or materials regarding time periods, products and medical conditions 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 To the extent it purports to seek information or matenals regarding the working conditions of Abex employees, this interrogatory is further objected to on the grounds that such information or matenals lack relevance to the issues ansing in these cases and are not reasonably calculated to lead to the discovery of admissible evidence Abex objects to this interrogatory on the ground that it assumes the truth of matters not established or matters not m evidence -130-

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Kehoe Bettering Laboratory of .Applied Physiology University of Cincinnati Cincinnati IS* Ohio Dear Dr* Eehoel Thanh you very much for your thoughtful letter and comments regarding the paper Z sent you* I would not wish to convey the impression of fault finding and certainly of any particular group* My reference to blood lead has, as its aim* the too readily accepted values of many routine analyiets* Tour discussion of the several points mentioned will, of course, be very welcome, and I trust that the Conference as a whole will* if nothing else* impress tpon the members the importance of care in the diagnosis of lead poisoning.

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

Lead (Milligrams per liter). .............. .....

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.

Abex further objects to this interrogatory to the extent to which it seeks information regarding time periods and products that are not at issue in this case, on the ground that such information lacks relevance, and is not reasonably calculated to lead to the discovery of admissible evidence.

;Job Code Instrument HAZARD VCM Lead Total Dust ___ Time ?

Kehoe: I have been asked to recommend a maximumlead content for white gasoline which has been stored or transported in containers and lines previously carrying leaded gasoline.

July 20, 196k To All Mwn of the teed Industrie# JUioclttloe, lac.i k v xnaDta roe k f t al aaal t s x s Since our Met loo In th Lead Informatics Bulletin last year of atomic elaorptlco spectroscopy u an Important nsv etbod for the analysis of lead end other Mtalllc elements, there has taen a (ood deal of interest expressed by our eesbera In the s-hjcct nod cor*!!

Ienzotti Lead Free Faint Products cm TO kCTTio or uUljT 21, 4.9T1 DiCTtrc; iv Ve aake the following price list they are all lead free.

PJ-PPM -Microgram$/M* --Micrograms/M^ --Milligrams/M^ --% PEL Sample Time. 80 HR<> PEL: Q --Micrograms/M* 115dBA->^ ^es / No AnahJ^ Y ~ Analysis Date NSHazard: VCM ( ) Lead ( ) Antimony!

Tie attributes the symptoms to the action of the lead.

To the extent this interrogatory seeks information concerning the working conditions of Abex employees, it is objected to on the grounds that such information lacks relevance to this case and is 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 ansing in these cases and are not reasonably calculated to lead to the discovery of admissible evidence.