August 24, 1993 Page 10 n Consents Method Number: NAP601Q Analyte/Parameter ALUMINUM CALCIUM IRON LEAD MAGNESIUM Dilution Result 1 8.36 1 415 1 1.35 1 .3 1 180 Prep Method; 3015 MDL PQD .15 .2 .1 .1 .0400 ,5 .4 .1 .1 .1 6010: ALUMINUM, CALCIUM, IRON, AND MAGNESIUM ARE REPORTED AT NO ADDITIONAL CHARGE.

r e p o r t e d a c a s e o f l e a d p o i ' - on in g due to the inhalation of dust containing lead.

With reference to the attached Exhibit 1 admit that Rogers is Source 4 referenced throughout the document but particularly described at the bottom of page 1223 and onto page 1224 Response to Request No. 1 See Preliminary Statement and General Objections Responding Defendant objects to this Request as burdensome vague ambiguous and not reasonably calculated to lead to the discovery of admissible evidence Responding Defendant can neither admit nor deny this Request for Admission as it was not the author of the referenced publication 2 Admit that Rogers utilized chrysotile asbestos in its manufacturing process in its plant in Rogers CT Response to Request No. 2 See Preliminary Statement and General Objections Responding Defendant objects to this Request as vague overly broad burdensome ambiguous and not reasonably calculated to lead to the discovery of admissible evidence Responding Defendant further objects to this Request because it is not sufficiently limited to a specific product location or time and thus seeks information that is wholly irrelevant to the present case and not reasonably calculated to lead to the discovery of admissible evidence By way of further answer and without waiver of the foregoing objections and subject thereto Responding Defendant states that some of its products manufactured at its Rogers CT facility utilized chrysotile asbestos as an ingredient 3 Admit that Rogers utilized crocidolite asbestos in its manufacturing process in its plant in Rogers CT Response to Request No. 3 See Preliminary Statement and General Objections Responding Defendant objects to this Request as vague overly broad burdensome ambiguous and not reasonably calculated to lead to the discovery of admissible evidence Responding Defendant further objects to this Request because it is not sufficiently limited to a specific product location or time and thus seeks information that is wholly irrelevant to the present case and not reasonably calculated to lead to the discovery of admissible evidence By way of further answer and without waiver of the foregoing objections and subject thereto Responding Defendant states that some of its products manufactured at its Rogers CT facility utilized crocidolite asbestos as an ingredient 4 Admit that the Rogers plant in Rogers CT emitted chrysotile asbestos fibers into the ambient air outside the plant Response to Request No. 4 See Preliminary Statement and General Objections Responding Defendant objects to this Request as vague overly broad burdensome ambiguous and not reasonably calculated to lead ~ to the discovery of admissible evidence Responding Defendant further objects that this Request prematurely calls for expert testimony Responding Defendant can neither admit nor deny this Request 5 Admit that the Rogers plant in Rogers CT emitted crocidolite asbestos fibers into the ambient air outside the plant Response to Request No. 5 See Preliminary Statement and General Objections Responding Defendant objects to this Request as vague overly broad burdensome ambiguous and not reasonably calculated to lead to the discovery of admissible evidence Responding Defendant further objects that this Request prematurely calls for expert testimony Responding Defendant can neither admit nor deny this Request 6 Admit that the Rogers plant in Rogers CT utilized asbestos every year between 1950 and 1980 inclusive Response to Request No. 6 See Preliminary Statement and General Objections Responding Defendant objects to this Request as vague overly broad burdensome ambiguous and not reasonably calculated to lead to the discovery of admissible evidence Responding Defendant further objects to this Request because it is not sufficiently limited to a specific product location or time and thus seeks information

Defendant further objects to this request for the reason that it seeks information which is irrelevant, immaterial and not reasonably calculated to lead to the discovery ofadmissible evidence related to the Defendant1 s jurisdictional contacts, if any, w

INTRODUCTION There is a great need for a simple chem ical test which will give- an early indication of dangerous lead absorption or incipient lead' poisoning.

Lead is especially bad for children.

Stucco and Concrete Paint ODP White Lead--Soft Paste--H Zilo Lead and Zina--Soft Paste-- Special Index ... ., 0007-SWP-000333246 SHERWIN-WILLIAMS PAINTER CRAFT FINISHES Sh e r w in -Wil l ia ms For Professional Painters --4 -- PAINTER CRAFT FINISHES Try this experiment next time you quote your price on a difficult job -- just say -- "I'll give you Sherwin - Williams Finishes throughout at this price."

White lead should parlor speeches.

Jossph Lead Co.

`lead* eaaa deaarited.

LEAD INDUSTRIES ASSOCIATION 4M ixmrreM awvs MM TOW 7, M.

Dear Sirs, WOODLANDS NORTH We regret to have to inform you that three of our daily-paid labourers are now in hospital suffering from suspected lead poisoning.

Defendant further objects to this request for the reason that it seeks information which is irrelevant, immaterial and not reasonably calculated to lead to the discovery of admissible evidence related to the Defendant's jurisdictional contacts, if any, with the State of Texas a

ICRC expressly objects to each and every discovery request to the extent that it seeks any information in those cases wherein a special appearance is pending for the reason that such discovery requests are not related to any special appearance motion or likely to lead to the discovery of evidence admissible in a special appearance hearing.

Jossph Lead Co.