Leaded 2inc 105 Talc Basic Carbonate White Lead Paste (Contains 10?

RESPONSE TO REQUEST FOR PRODUCTION NO. 8: Abex objects to this request on the grounds that it is burdensome, lacks relevance to this case and is not reasonably calculated to lead to the discovery of admissible evidence.

Chronic exposure to lead can affect kidneys, blood, gums, gastrointestinal system, and central nervous system.

Working with molten lead and acids. c.

Further objecting, the information sought is neither relevant to the subject matter of the pending action nor reasonably calculated to lead to the discovery of admissible evidence as it relates to Dana.

Abex further objects to this interrogatory on the grounds that the information or materials 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 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.

At this season of the year the hazard of lead exposure is loss than it is during '<no cola weatner 'this is the time, therefore, to plan and carry out the necessary steps.

TuUh, ' md fox tin lit stipple roil, bOU het per gallon For v,all v.oik ol anv description we will be glad at an\ time to highly recom mend DutchBoy white-lead and DutchBoyflattingoil," for tin Home. ' II you 1 iioivod a cop- , u I il i our in. ir.

ABDOO136601 \1LL ABERDEEN CHEMICAL PLANT INDUSTRIAL HYGIENE MONTHLY REPORT Month: October Date of Report: 11/15/84 Routine Chemical Dosimetry All Sample Results: Chemical VCM Lead Total Particulates PEL No. % 88 95.7 32 100 3 100 2: No.

Abex 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 matenals 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 ansing in these cases and are not reasonably calculated to lead to the discovery of admissible evidence.

War on Lead a3i>n*.fLcfl Is fnfensified Tbs city's Bursas ( Guinea said tha bweau recent-1 Ha said tha paint industry it- htaNhl Control will intaasify tohalSssSTto* crihi- thV f " l"t "* it* erarfedown m atrebuti and manufacturers srhn tn iUecsUy was li*i Htf1 I credibility on tha iaad oueatian nurketinr Mints hilh is lead can* Mat.

Westinghouse further objects to responding to this Interrogatory concerning any products not alleged to have contributed to the alleged injuries of plaintiff(s), on the grounds that the Interrogatory, as applied to Westinghouse, is overly broad and unduly burdensome and seeks information which is irrelevant and immaterial to these proceedings and is 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 lack relevance to the issues arising in these cases and are not 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 ground that such information or materials lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence.

CABLE CONFIRMATION Cable received from To_ S C /f a D esp atch ed 141 *4 3 Date - ^ e e e i ^ e d - l -5 ,la4 3 -- ROBER T K E UDE K E T T E R IN G LABORATORY C IN C IN N A T I RAY BEVAN CODK USED T RA NSL A TI ON D S E OF LEADED G A SO LEN E I N B I O T TO RCH ES S T O V E S AND LA M PS YETTHEN ROOMS OR EN C LO SED S P A C E S I S D E F IN I T E L Y DANGEROUS F O R MOHS THAN SHORT P E R IO D S IN EMERGENCY BECAUSE OF A IR CONTAMINATION STO P CONTACT OF FOOD WITH FLAM S O R FR E E FUME IN OVEN G IV E S FURTHER SIG N IF IC A N T CONTAMINATION STOP U N LESS MEANS FO R REMOVAL OF LEAD FROM F U E L OR W ITH IN COMBUSTION EQUIPM ENT I S PR O V ID ED NONIEADED FU E L IM PERATIVE FO R GENERAL REGULAR U $ g ROBERT NEEDS EET3ER EN G LABORATORY CIN C IN N A TI Copies to : HE <JUO c, c n ( N 7811