Defendant objects to Definition No. 1, attempting to define`T)efendanf',``you'',``your" and "your company" to include legally separate and distinct corporate entities who are not parties to this case on the grounds that such is overlybroad, unduly burdensome, harassing, not relevant and not reasonably calculated to lead to the discovery ofadmissible evidence, and goes beyond the scope ofdiscovery under the Texas Rules of Civil Procedure. 3.

QUINTO TIJERINA GAF CORP., ET AL PLAINTIFF'S EXHIBIT MON-377 CAUSE NO. 00CV1037 .

Crane Co. objects to these Discovery Requests to the extent they are unduly burdensome and overbroad, or seek information that is neither relevant to these actions nor reasonably calculated to lead to the discovery of admissible evidence.

23 discussed lead in human health?

In addition, the Defendant makes the following specific objections: The Defendant objects to the definitions of "Defendant", "You", "Your", and "Your Company"as being overly broad, vague, burdensome, harassing, and not reasonably calculated to lead to the discovery of admissible evidence.

T Martmott contents Seep H TOP OF THE NEWS 11 Lead phase-down in gasoline poses threat to key petrochemical feedstocks. 13 Mississippi proposes phase-out of mirex production and use by mid-1978. 14 Goodrich.

Oc cupational diseases reportable by name, address, age, sex. race/ethnicity, method of diagnosis, and relevant occupation(s) and employees) of the case, and identity of the reporter, are: SRHB3P silicosis, blood lead levels at or above 40 micri>grams lead/100 milliliters of blood in persons 15 years of age or older, and acute occupational pesticide poisoning.

Crane Co. objects to these Discovery Requests to the extent they are unduly burdensome and overbroad, or seek information that is neither relevant to these actions nor reasonably calculated to lead to the discovery of admissible evidence.

TUON-enwSTANTAN EXTENSION LEAD WIRE Insulation Temp.

There is no business which is more eas ily handled or that leads to big S.

We are 20 more interested in keeping ins lungs free from poisonous dusts and gases, his bones free truin lead, his liver free from chlori nated solvents, etc.

Therefore, the response ofNSRC to such interrogatories could not lead to the discovery of admissible evidence.

Crane Co. objects to these Discovery Requests to the extent they are unduly burdensome and overbroad, or seek information that is neither relevant to these actions nor reasonably calculated to lead to the discovery of admissible evidence.

Lead, Lbs.

Crane Co. objects to these Discovery Requests to the extent they are unduly burdensome and overbroad, or seek information that is neither relevant to these actions nor reasonably calculated to lead to the discovery of admissible evidence.