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 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 arising 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.

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 To the extent it purports to seek information or materials regarding the working conditions of Abex employees, this interrogatory 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 Abex also objects to this interrogatory on the ground that it assumes the truth of matters not established or matters not in evidence.

Page New York REPORTED LEAD POISONIKG CASE L `*'; lO : February * .

Page -i I REPORTED LEAD.

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

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.

. ,, -- Shift '---------- ^pew -nwv/vo /w/*i gwrif/ty m N9 0993 A Dare /-/- Social Secur ity No.Job Code --~~~~~ 0Inctriimant Nn / Tima Start ft - 30 Stop ) 4-^ AM{ )Pfclf ) Airflow HAZARD VCM Lead Antimony Total Dust Noise Sample Tima Q'O C --Micrograms/M^ g --Miaograms/M --Milligrams/M^ --% PEL PEL: --Micrograms/M^ 115 dBA^ Yes / No /Ay Analvsf V A Hazard: VCM ( ) Lead ( ) Antimony ( ) Oust ( ) Noise ( ) J ) NS 1.

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.

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.

Superintendent of the national Lead Company Steel Package Plant in St.

They compare very well with results obtained consistently on young healthy experimental subjects selected on the basis of a completely negative history with respect to lead exposure.jin as much as the blood and urinary findings are mutually confirmatory in that both are entirely normal I see no reason for making any further observations

As you know the finding of stipple cells is not psthognostic for lead poisoning but is also often found in all kind of anemias."

1CEMOBA5IPM FCR DIRECTORS* MZETIHC- - OCTOBER 27, 194-2 HEf qjBBOT AHD OTHER ASSETS - SEP'pgtfREB 30. 194-2 CURREgT ASSETS: Supplies Metala: In Process Finished: Lead Copper Silver Cold By-Products 11,768,107 lbs. 4.833# 16,022,712 lbs. 9.141# 2,003,029 ozs. a 38.564# 16,754 ozs 0 $34,180 '* Reserve for Freight and Refining Manufactured.

AM(V)PM( ) HAZARD VCM Lead Total Dust Airflow_______________ ^srasj^Taa?

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