Document dQykLqXyaKqZwbR5QprYb8GDG

There are approximately 75 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 denved, details of which are as follows. 1 Histoncal material 2 Promotional matenal. 3 Product brochures. 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 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 has segregated and/or tagged certain documents with respect to which it claims privilege The best specificity that Abex can presently provide as to the documents with respect to which it claims privilege is as follows. Documents passmg between Abex and/or its predecessors or -23-