Document omp0xGaRz4vgmjBJeNZm8B56o

contained in the repository for purposes of copying or preparing their own abstracts or summaries. There was never a central corporate filing system of Abex records and documents. Therefore, the burden of deriving or ascertaining the response to this interrogatory, if at all, is substantially the same for plaintiffs as Abex. There are approximately 200 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, the subject matter of which includes but is not limited to the following: 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, Friction Materials Standard Institute ("FMSI"). Pursuant to Illinois Rules of Civil Procedure, plaintiffs will have a reasonable opportunity to examine, audit, inspect and to make copies, compilations, abstracts, or summaries ofthese boxes of documents, which will be produced to plaintiffs at Abex's facility in Brooklyn, New York, where they are maintained in the normal course of business, should plaintiffs decide to inspect them. 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 ofdocuments, 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 passing between Abex and/or its predecessors or divisions, 193