Document k9wjvY77Lq8d4epbodZVk0awq

There axe approximately 125 boxes, many of which compnse of approximately 2,000 - 3,000 pages, that contain the documents from which the response to this interrogatory maybe ascertained or denved,details ofwhich are as follows- 1. Club Membership, 1980-1981 2. Asbestos Information Association, 1977 3 Expense Reports, 1980-1982 4. Abex News and other miscellaneous pubhcations, 1967-1978. 5 1970s-1980s Subject Files, FMSI. 6. Subject Files, Fnction Products Division. Pursuant to the Illinois Cpde 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 of business, 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 to the extent it purports to seek medical records or privileged personnel information. Abex will not provide such information absent an appropnate 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 -225-