Document 1gjdDeQv3KkzqY77YyYVvoeRX

There are approximately 125 boxes, many of which comprise of approximately 2,000 - 3,000 pages, that contain the documents from which the response to this interrogatory maybe ascertained or derived,^details of which are as follows: 1. Club Membership, 1980-1981. 2. Asbestos Information Association, 1977. 3. Expense Reports, 1980-1982. 4. Abex News and other miscellaneous publications, 1967-1978. 5. 1970s-1980s Subject Files, FMSI. 6. Subject Files, Friction Products Division. Pursuant to the Illinois Cpde of Civil Procedure, plaintiffs will have a reasonable opportunity to examine, audit, inspect and to make copies, compilations, abstracts, or summaries f of these boxes of documents, which will be produced to plaintiffs at Abex's facility in Brooklyn, New York, where they are maintained in the ordinary course of business, should plaintiffs decide to inspect them. To the extent that any of the documents that plaintiffs decide to inspect were prepared in anticipation of litigation or for trial or are otherwise covered by the work-product doctrine, or are protected from disclosure by the attorney-client privilege, Abex also objects and will not make such documents available to plaintiffs. Abex further objects to this interrogatory to the extent it purports to seek medical records or privileged personnel information. Abex will not provide such information absent an appropriate waiver of the applicable privilege. Abex has no comprehensive list or log of the documents with respect to which it claims privilege. In the past, when Abex has had cause to review some boxes of documents, it ( -225-