S OBJECTIONS TO PLAINTIFF'S NOTICE OF CR30(b)(6) DEPOSITION- 2 4218898.1 Williams, Kastner & Gibbs PLLC 601 Union Street Suite 4100 Seattle, Washington 98101-2380 (206) 628-6600 1 RESPONSE: 2 JMM incorporates herein its Preliminary Statement and General Objections and further objects to this request on the following specific grounds: the request is overbroad, 3 overly burdensome, lacks foundation and is not reasonably tailored to the facts of this case, and seeks information and documents that are not relevant or reasonably calculated 4 to lead to the discovery of admissible evidence.

Formula for 116 White Lead Paint. 2.

Defendant objects to the stated definition of the terms "products containing asbestos fiber," "asbestos containing products" and "asbestos products" on the grounds it is overly broad, vague and not limited to the matters made the basis of this lawsuit and therefore, seeks disclosure of information and/or the production of documentation wholly irrelevant to any material issue in this case and not reasonably calculated to lead to the discovery of admissible evidence.

Outstanding in the divisions of work ia this plant are Tin Can Manufacture, White Lead (Dutch and "Quick* processes).

LEAD INDUSTRIES ASSOCIATION 420 LEXINOTON AVKNUC NSW YORK 17, N.

The lead was weighed into PVC bags and sealed.

Louu j 6 (National Lead Co. of Mo s j .) 0000-NU-000016052

LEAD INDUSTRIES ASSOCIATION 420 LEXINOTON AVKNUC NSW YORK 17, N.

We will gladly purchase this material in order to releave our minds concerning the "lead menace" .

Would it be possible to Incorpor ate this on the lead labels also?

Brown 1500 Rhode island a m, b .w * Washington, D*C* 20005 Mr Roys If yon accept the premise that any risk of lead ingestion is bad, -then a reduction in the amount of lead in paint exposed to children must he regarded as progress* However, as we both know, there currently is not sufficient data to firmly establish what amount of lead in .paint is safe*" in view of the federal regulation limiting lead to 0.5*, I would support adoption of 'the proposed revised standard provided that it is scheduled for early review as sera data evolves* Very truly yours.

Titus 1 Thank you for your letter of May 27 regarding the rapid lead teat described by Drs.

M* Oerter, Chairman of the lead Pignents Division of the lead Industries Aeeooilatiott, has ad^Alue to pxevfde you with a oopy of the, Hester Code of the Lead Industrie* Association, together w$fflFWgwm'0$ the Xtndea of the two meetings of the Division whioh hate ** far been held. .* Aooordingly, I as pleased to enclose a oopy of ouf Coda as it was filed in Washington and the minute* of the meeting of August 8th, Dry ProductsOowBittes, and ^ August 9th, white Lead-in-Oil Coanitte*. .

Mltehellaon wanted to know lead content.

Joseph Lead Co.