This Request is vague, ambiguous, overly broad, unlimited in scope and seeks information which is neither relevant nor likely to lead to the discovery of admissible evidence.

This Request seeks information which is neither relevant nor likely to lead to the discovery of admissible evidence.

HOTS 3 - Anaoonda Lead Prodaot* Company at December Slat 1935 waa 8*#01Jt owned by registrant.

Motor Lead ML "WtBTOS A.V.C.

Ineoae firca Frenek Oxide produetlea wrar ms gxpwiigiT---i 4. 1,700 1,900 4,100 Tbe 1store for Xarek ate aa foilovss Cry Fbite I.ead Zhite Lead-in-011 410,880.43 3,497.11 TJse xtalte Lead Eepartaent iti i aoatk belig doe to Shut- daws Xxpenee.

186,625 lbs. 57,231 it tt " 100% tt " 89% tt " 93% it " 90% BOUND BROOK INSECTICIDE - Lead arsenate Arsenic Acid Sodium Arsenite * Snfe-N-Lead Continuous operation. 135 tons 85 n 35 tt 30 it Eordo Mixture Paris Green Dry Lime Sulfur Calcium Arsenate 15 ton 7" 1" 1" OAKLAND INSECTICIDE - 5 days--three 3 hour sshifts AC;.E .LOWE BROTHERS COMPANY LUCAS Produced 43,387 gels.

Pb per gm. ash Lead in Faeces mgs.

Asbestos Personal m,ui Abrams Lead & copfeo ..

This Request seeks information which is neither relevant nor likely to lead to the discovery of admissible evidence.

Lead sheath.

Secretary iona Shite Lead and 0 olor forka, 11 Mala St., Buffalo, V.T.

This holder assembly adapts the Model S pump to chem ically detect chromic acid mist and lead dust and fumes.

Information of this nature is being supplied because it may lead to the discovery of admissible evidence.

The certainty that this will be done frees us of any very great fear about the lead hazard during the cleaning operation.

To the extent that this was Plaintiffs' intention, LuK AS objects that such undertaking is overly broad, unduly burdensome, harassing and not reasonably calculated to lead to the discovery of admissible evidence.