Document jmdD7XX6vpOEnb363QrGgJ7x2

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 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 in Brooklyn, New York, where they are maintamed m 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 doctnne, or are protected from disclosure by the attorney-client pnvilege, Abex also objects and -194-