Document LKkwVMnojgae8N6BJa1D7jJ53

with personal knowledge of the information contained m 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 ofpreparing or making such a compilation, abstract, audit, or summary would be substantially the same for plaintiffs as for Abex. There are approximately 100 boxes, many of which comprise of approximately 2,000 - 3,000 pages, that contain the documents from which the response to this interrogatory may be ascertained or derived, details of which are as follows 1 Research and development. Raw matenals. 2 Lab notebooks, Product development 3. Subject files 4 Engineering test results. 5 Formula, testmg, and development 6. Production/testing research 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 m the ordinary course of business, should plaintiffs decide to inspect them -109-