Document DGb1pzmYv5EKZOR8ZXpQ6oz5n

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 165 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 7. Medical Department Records 8. 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 m Brooklyn, New York, where they are mamtained in the ordinary course of busmess, should plaintiffs decide to inspect them To the extent that any of the documents that plaintiffs decide to inspect were prepared m 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 -215-