Abex further objects to this request 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.

KEEP LEAD OPERATOR INFORMED OF YOU ACTIONS AND CONDITION OF COOLING TOWER. .3.

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. -34-

Twice as much of the $% calcium naphthenate .9 25% lead naphthenate is a good average to use.

BPS House Paint Exterior House Paint White 218 First o I 89 CJt t Oo Mto \ + to M i Pigment: 65$ leaded Zinc (62$ lead) Titanium Oxide Asbestine Vehicle: 35$ Refined linseed Oil Raw linseed Oil Bodied linseed Oil Processed linseed Oil Mineral Spirits Brier Drier / Calculated Yield' Yield in Unit Total kb'___ Gallons Coat_______________ Cost 780 104 156 186 263.5 32. 24. 45.5 10.6 10.6 -,,^>45 7 15.4 sjifitO?

mctaujc lead wKcsuers c*top OctaUr 1?

At the risk of causing some reiteration on your part, we should like to inquire if you feel that such a tank is entirely safe from lead hazards?

Abex further objects to this request on the grounds that it is compound, vague, ambiguous, overly broad as to time and scope, unduly burdensome, irrelevant to any issue in this action and not reasonably calculated to lead to the discovery of admissible evidence.

Abex objects to this interrogatory to the extent it purports to seek information or matenals regarding time penods and products that are not at issue m these cases, on the ground that such information or matenals lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence.

CO., Philadelphia NATIONAL LEAD 6c OIL CO..

* nawswrti I>T * t iti'firnilimJuiiHimmi At* ne i ar. r*w<i- > ----- LEAD INDUSTRIES ASSOCIATION 4M UBOMrrCN AVCNUI MM TOM tT, A V.

A baffle for the fire end of the large kiln to improve dust collection and reduce airborne lead dust.

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.

~/S-73> TRAINING BY VINYL FOREMAN TRAINING BY LEAD OPERATOR * (NAME OF UTILITY) FOREMAN'S UTILITY'S LEAD OPER.

, known sa the ILLIKD tbtLTIHG- COMPa KY, whose entire, occupation consists in the reclaiming of lead from dis carded storage batteries,, most of them-automobile batteries, le have beeiC for a, long time:, in receipt of Teoeafed oonmlaints of obnoxious odors, sminat-ing from this slant, nr incisal Iv, hydro ;;en sulphide, and sometimes apparently, sulnher' dioxide. 7:vey make a. nractice, s,s I understand it, of--burning the wooden separators in such batteries, and of melting and reclaim ing the lead.