Of course, the waouni and rate of cpettier.* has eocse bearing, on ooli life] however* a hirier factor is probably the aasourtt of Micter.ance and petering perferaod when nearing the end of a aervice life, which beeoooa an eeanoaie balance of repair vs, repl&ccetent* Ultiaste failure of any lead ooll usually arises because of typical swelling or blister formation.* Very truly yours, i ^s^rs-vs; N3096

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 Abex objects to this interrogatory on the grounds that the information or materials it purports to seek otherwise lack relevance to the issues arising m these cases and are not reasonably calculated to lead to the discovery of admissible evidence v Abex also objects to this interrogatory on the ground that it assumes the truth of matters not established or matters not in evidence Subject to and without waiving these objections, insofar as Abex understands this interrogatory, and upon information and belief, some of Abex's asbestos-containing automotive friction products were generally packaged in plain, brown, or tan cardboard boxes according to size, with the end label being imprinted with colors The brand name appeared on the packages as did the product name Abex packaging varied from product to product over the many decades of its corporate existence Upon further information and belief, Abex has no sample packages. -65-

* t 1 f^stbn Sid White Lead ... ;>, ... .i .

this interrogatory because it is vague, burdensome, broad, and is not reasonably calculated to lead to the discovery of admissible evidence.

Notify WTU or lead operator. 7.

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.

ANSWER TO INTERROGATORY NO. 36: Abex Objects to this interrogatory on the grounds that in seeking information concerning Abex employees, it lacks relevance to this case and is not reasonably calculated to lead to the discovery of admissible evidence.

It has therefore been suggested that we contact you so that the proper order can be issued to your local bulk plant representative to hold for our tests five 50-ga.llon drums previously used for aviation or other leaded gasoline.

.; n o t c o r r bo t an d o t h er as s et s - j l -l t 31. 1342 guaaara as s et s Supplies Metals* In Process Finished: Lead Copper Silfer 0014 By-Products 15,4-68,226 lbs. o 5.14?

Abex further objects to this interrogatory oh 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 ofadmissible evidence.

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.

We have Ju st received an in quiry concerning the p o ssib ilit y of sign ifican t lead absorption in the handling of putty cut with lead gasolen e.

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.

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 reasonably calculated to lead to the discovery of admissible evidence.