A sheath was placed over the 0.0035 wire and a fine line ventricular lead was placed.

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.

H 0020585 Ratio of Methanol Hazard to Lead Hazard, Date 9-8-43 9-8-43 9-10-48 9-10-48 9-I3-48 1ine n / rt r 1C;05 it* r~. li- 10:30 a.rn.

y the reports which I have seen as yet), and {2) what change occurs in the distribution of lead in the body, following its administration.

I have no hesitation in telling you that in my opinion, the conditions with respect to lead exposure are quite hazardous.

It appears that Mr. mjl^^ad had very little lead absorption in the period shortly before the collection of these samples.

t t LEAD INDUSTRIES ASSOCIATION [ AM I miHTOII AVDIUK I' mw TOO* 17, K.

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.

. #2 to provide more air here* 4) Ho comments - based on their comments* Rolling 5c) Minimal concentrations of airborne lead exist at rolling machines except backing machine #6* (a) It is apparent that several conditions exist in the fume hood system, due to "poor* maintenance.

ANSWER TO INTERROGATORY NO. 21: 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 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 further 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 Subject to and without waiving these objections, and insofar as it understands this interrogatory, Abex has not found any documents whereby Abex agreed to rebrand and sell under its own name asbestos-containing brake products manufactured by someone else In addition, see Answer to Interrogatory No 10 -55-

LEAD INDUSTRIES ASSOCIATION MOVOMKIT.ICV.

Mr* Wilaon summarized the visit which ha had made, together with member* of the New lark office and tho Now fork laboratory, to the company* a Sayvill# Experimental Station on Friday, dune 11* Panels of various formulations of White-Lead and Hod-Lead Paint wore examined to the satisfaction of all those in attendance* The regular weekly reports of shipments for the periods ending June k and June 11, ware praseated by Hr.

. |^'4^4 DeartQseart^l ^Mrt^viShSH. s^tef 4W/fc*if ^ - *r --t**il -ssa opera^r^ im- t&sr ,,4 "' % On April' $, Lea" Huxtable wrote relative to a supposed lead .

KEEP LEAD OPERATOR INFORMED OF YOU ACTIONS AND CONDITION OF COOLING TOWE'R. 3.

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-