RESPONSE TO INTERROGATORY NO 7: Garlock objects to this Interrogatory on the basis that it is ambiguous, overly broad, unduly burdensome, and is not reasonably calculated to lead to the discovery of admissible evidence.

Iron, chromium, lead.

For instance, the research that is being conducted constantly by our Chemical L Pigment Division; Euston Lead Division; Metals Refining Division; Haval Stores Division; Soya Products Division and Vegetable Oil Division has contributed time after time to innovations and product improvement in the Paint Division which otherwise might not have been accomplished or would have been delayed.

Forbes su bjec t Alleged Lead Poisoning Case a ddr ess New York a ddr ess Philadelphia dat e March 17, 19-47 Attached herewith please find the file con- ' cerning an alleged lead poisoning case forwarded by Mr.

Forbes s u b j e c t Alleged Lead Poisoning Case a d d r e s s New York a d d r e s s Philadelphia DATE March 17, 1947 Attached herewith please find the file con cerning an alleged lead poisoning case forwarded by Mr.

LEAD rg.Ttnvr d r apt oourrrmu.

With time out to secure a commission in the Chemical Warfare Service in World War I, he has climbed upward through Eastern Industrial Sales, Euston Lead, and Metals Refining to his present position ns a VicePresident of The Glidden Company in charge of sales of Euston Lead, Metals Refining, Chemical & Pigment Division und The Soya Division.

The plant feels that a calculation error was made in the lead analysis.

C, .1H2 on lead In oil and slnooxlda shipped from Vatfark,-)?.?.

RESPONSE TO INTERROGATORY NO. 7: Garlock objects to this Interrogatory on the basis that it is ambiguous, overly broad, unduly burdensome, and is not reasonably calculated to lead to the discovery of admissible evidence.

Flashing materials vary with conditions at building site but sheet lead is generally rec ommended. 12.

He should not be su b jected to any fu rth e r ex p o su re to lead and should not resu m e w ork u n d er conditions of ex p o su re until he h as re tu rn e d to the n o rm al range of lead concentration.

Lead Foisonincr.

Lab rvisor/Lead Gold Bond Building 1650 Military Road Buffalo, NY 14216 ATT: Rob Kwapisc Products VAB.0001193585 r-V*,VV.' ' ^, * .

Such information is not relevant to the subject matter of this action and is not reasonably calculated to lead to the discovery of admissible evidence. 3.