.&8& ujxnjjima. k , in To Masters of tba taad Xoduatrlaa Association, Xhe.t "tba Saqpalaa of Flea Kith and Without Lead Folxxilnf* $,Ski* artlela rayrlnted frca tba UttOCSM JCWW1 OF tHEEASJS OF CHUXWBt, ' Ju d * 196}, Toll-- 10 pa**t 609-616, npnwaU tba first St*t* of * tudy apooaortd la put by LU u nmnl designed to inraatlgat* th* probl-- of lead poisoning la yew* children.

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 purports to shift the burden of establishing product identification from plaintiffs to Abex i Abex further objects to this interrogatory to the extent it purports to seek information or matenals regarding time penods 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 ansing 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 m evidence.

ANSWER TO INTERROGATORY NO. 33: Abex objects to this interrogatory on the grounds that it is overly broad, burdensome, lacks relevance to this case and is not reasonably calculated to lead to the discovery of admissible evidence. 34.

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.

11 RESPONSE TO INTERROGATORY NO. 24: 12 Wagner objects to this interrogatory on the grounds 13 that it is overly broad, unduly .burdensome and not calculated to 14 lead to the discovery of admissible evidence. 15 INTERROGATORY NO. 25: 16 Is there any dispute as to insurance coverage with 17 respect to claims made by plaintiff?

(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-

I should judge that what Dr- Morrissey is talking about is an acute contact dermatitis rather than acute lead poisoning, but we shall see.

Defendant further objects to the definition of these terms as calling for the production ofmaterial or information which is neither relevant nor reasonably calculated to lead to the discovery ofadmissible evidence.

Defendant further objects to the definition of these terms as calling for the production ofmaterial or information which is neither relevant nor reasonably calculated to lead to the discovery ofadmissible evidence.

U.

GLI>?.

.,44 Mill White....................................................... 42 l^otor Soap...... ................................................ i;j ,,, 46 New Process Red Lead .................................................... 66-17 Eon-Corrodable Acid-Resletlng Paints....................... 28 * ?

., Chicago In discussing the determination oi injuri ous dusts, fumes, gases and vapors, I am very sure that you are not interested so much in a meticulous dissertation on such phases of the subject as whether the loga rithm of the reciprocal of the hydrogen ion should be 9.5 or 9.0 for the determination of lead by the dithizone method, but rather in a discussion of this matter along broad lines, pointing out what types of potentially injurious materials should be looked for, whether determination of them is in order, a brief discussion on some of the more im portant and common methods of determina tion, and interpretation of the results ob tained.

Year 1944 Year 1945 1955 Tooele plant $ 394,775.34* Miami plant 133,925.85 Lead refinery 32,969.95 Zinc oxide department 90,618.19* White lead department 16,823.58* Raritan refinery 1,216,453.14 Raritan electro-eheet department 34,409.58* Not allocated (details page 42) 82.344.37* 344,208.98* 147,172.64 36,223.72 1,890.97* 21,701.99* 729,523.18 21,545.80* 111.354.70* 439,979.09* 11,911.49 40,358.34 73,431.83 19,265-33* 831,863.17 15,457.07* 141.420.85* 4,319,552.69 1,213,288.11 741,319.56 864,975-51 445,099.24 6,394,=39.75 286,056.6c 476.944.56 Net profit on plant operations as above $ 764,377.88 412,217.10 341,442.49 14,741,773.08 Details of the above figures: for 1945 are shown on the Belance Sheet and Income Account by departments on pages 14 and 15 respectively. 5 Income (Loss*) from sundry Investments Investment at December 31, Year 1943 Year 1944 Year 194*; 19*5 National Tunnel & Mines Company, Interest $ 44,365.37 *8,751.09 14,558.22 -- Walker Mining Company, lost on note Other investments advances - - 44,273.75* -- (details page 41) 112.110.60* 159.1S6.36* -55,994.81 1,137.639.77 Income (Loss*) from invest ments - per page 4 $ 67,7*5.23* 110,605.27* 26,279-28 1,137,839.77 Details of the above figures for 1945 are shown on the Balance Sheet and Income Account by departments on pages 14 and 15 respectively.