Document 152EYan1qZLOmB8oB55JNy30a

to Abex's purchase of S.K. Wellman Company. Upon further information and belief, following its purchase by Abex, S.K. Wellman business may have sold asbestoscontaining friction products. In addition to the foregoing, Abex discontinued the manufacture and sale of asbestos-containing friction products m 1987 and no longer operates any friction product manufacturing facilities There are no current Abex employees, officers who worked for Abex, or directors who sat on its Board during the period Abex manufactured and sold friction products with personal knowledge of the information contamed in all the records and documents that might be responsive to this interrogatory. The available information, from which Abex would prepare a response to this interrogatory, is contained m files and records maintained by Abex. To prepare a response to this interrogatory would necessitate the preparation or the making of a compilation, abstract, audit, or summary of or from these files and records. No such compilation, abstract, audit, or summary presently exists. The burden and expense ofpreparing or making such a compilation, abstract, audit, or summary would be substantially the same for plaintiffs as for Abex. There are approximately 75 boxes, many of which comprise of approximately 2,000 - 3,000 pages, that contam the documents from which the response to this interrogatory may be ascertained or derived, details of which are as follows. 1. Historical material 2. Promotional matenal 3. Product brochures Pursuant to the Illinois Code of Civil Procedure, plaintiffs will have a reasonable -13-