s B ureau o f Lead P o iso n in g C o n tr o l, d is c lo s e d th a t te n c o m p a n ie s a r e s e l l i n g h ig h ly le a d e d p a in t s i n v i o l a t i o n o f th e New York C ity H ea lth C ode.

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.

Arrange the factors in order of decreasing importance by placing the appropriate number to the left of the factor with 1 being the most important. ________ Target Industry - Those industries with poor accident and health records such as lumber and wood products, roofing and sheet metal, mobile heme manufacturing, longshoring, industries with high and repeated exposure to harmful materials such as asbestos, cotton dust, silica, lead, carbon monixide. ________ Random selection ________ An accident or industrial disease which involved a fatality or requires the hospitalisation of 5 or more persons. ________ Employee complaint of an GSHA violation. 3.

RECENT R&D RESPONSE TO LAWS REGARDING LEAD AND MERCURY: Laws are in force to protect the consumer from the hazards of lead poisoning.

Shell objects to providing information relating to "Defendant's predecessor" or "Defendant's subsidiary companies" as being overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence.

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

purities as lead, cadmium, and arsenic are "brass founders' ague."

Table I comparer thdtaew aod coat foe lead aloeie rema mm partatwa amcriak.

ACandS objects to this interrogatory on the ground that this Interrogatory is vague, overbroad and not reasonably calculated to lead to. the discovery of admissible evidence. 4.

purities as lead, cadmium, and arsenic are "brass founders' ague."

White lead CJLt- 1 .

!

Defendant objects to Definition No. 1, attempting to define "Defendant", "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 overly broad, unduly burdensome, harassing, not relevant and not reasonably calculated to lead to the discovery of admissible evidence, and goes beyond the scope of discovery under the Texas Rules of Civil Procedure. 3.

H-02SJ of the Chief Counsel, Attention; Rules standard on lead.