Document M4vzeO3gj9NdYKmKDOzJnnvKV

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 165 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. 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 in Brooklyn, New York, where they are maintained in the ordinary course ofbusiness, 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 -194-