Document 3N9Nzy0VvyewZaDXG8mZ4L6bE

information contained 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 in 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 of preparing or making such a compilation, abstract, audit, or summary would be substantially the same for plaintiffs as for Abex. There are approximately 150 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. Winchester quality control. 2. Production plans. 3. Subject files, Friction products division. 4. Blueprints, Friction products division. 5. General correspondence. Pursuant to the Illinois Code of Civil Procedure, plaintiffs will have a reasonable opportunity to examine, audit, inspect and to make copies, compilations, abstracts, or summaries 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 ofbusiness, should plaintiffs decide to inspect them. -171-