ANSWER: ACandS objects to this interrogatory on the grounds that it is overbroad and seeks information not reasonably calculated to lead to the discovery of admissible evidence since, among other things, it is not limited to the relevant time period, geographic area, or to the products to which the plaintiffs allege exposure.

ANSWER: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, lacks relevance to this case and is not reasonably calculated to lead to the discovery of admissible evidence.

TASK DETAILING - A reference list of the subtasks necessary to perform the tasks in the module SL 0112Q7 COWFiPSHTlAtl Abject to protective J*6* L4th Judicial District Court YOUR ON-THE-JOB TRAINER, LEAD OPERATOR AND SUPERVISOR WILL ASSIST YOU DURING YOUR TRAINING PERIOD.

**o Vn *3 HWBB-0007877 6Z8/00B-88H Hygiene Foundation of America, Inc., 4400 Fifth Avenue, Pittsburgh, Fa., January 10, 1938 .

PLIBRICO objects to the instructions and definitions as outlined in the Plaintiffs interrogatories as overly broad, burdensome and not reasonably calculated to lead to the discovery ofadmissible evidence.

Defendant further objects to the definition of these terms as calling for the production ofmaterial or information which is neither relevant nor reasonably calculated to lead to the discovery ofadmissible evidence.

Kn <X} HW6B-0007877 HhBB-0607879 Hygiene Foundation of America, 4400 Fifth Avenue, Pittsburgh, Fa., January 10, 1938 Inc., REFERENCES TO RECENT LITERATURE ON INDUSTRIAL DISEASES (A) Nowa Items 1 CUTOD HOUSEKEEPING A D SAFETY IN FOUNDRIES AND INDUSTRIAL CODES AND OCCUPATIONAL DISEASE LEGISLATION.

-MAKETAOinKli Or HAMrfn. ..tira Acme White Lead & Color Works, of Detroit.

April Handcuffing the Saboteur (FBI) April Subs off the Gndercllas (Aruba) April Beating the Bombers (Air Raid Precautions) April We Taught Them How to Fight (American Inventions) May Soybean War Baby May Spring Geography Lesson (Kamchatka and Aleutians) May Women Man the Machines June Things to Come (Life in Wartime) June Lead--Ugly Duckling June Streamlined Job Training June What Are the Japs Fighting For?

WORU 11-12/44 p. lfl t 1910 MAHUPACTURE OP WHITE LEAD bp old Dutofa prooaaa waa begun in the Chicago Plant.

Acme W hite Lead & C olor TForke Report o f Receipts 0007 S W 000033823

% of Subjects % of $ub|octs DISTRIBUTION BLOOD LEAD HoodFbftg/lOQg 3 3 3 S N 27017 DUP040005891

-LEAD POISONING POTTERY UJ a n** i- cj ri 2 K 12

Chemical Company For lead analysis of the excreta as requested by Dr.

. * Jor freight charges on 2 hblo. of Vhite Lead . tMr attaahad.