Document pBkOJndBddebrbnQMp7D7dvVB

REQUEST FOR PRODUCTION NO. 51: If this Defendant claims that the documents are too voluminous to produce as requested, provide the following: (a) The numerical amount of documents responsive to requests herein; (b) The method of storage of documents responsive to requests herein; (c) The method of organization of documents responsive to requests herein; (d) The location of documents responsive to requests herein; (e) Whether there is an index or indices, lists, inventories, or other such information for records responsive to requests herein; (f) If there is an index, indices, lists, inventories or other such information for records responsive to requests herein, whether such index, indices, lists, inventories or other such information for records responsive herein is printed, or electronically stored, (i.e. listed in a computer, imaged, part of a database, etc.). (g) If the index, indices, lists, inventories or other such information for records responsive to requests herein, whether such index, indices, lists, inventories or other such information for records responsive herein is electronically stored, (i.e. listed in a computer, imaged, part of a database, etc.), the method of such storage and software used to create and/or maintain said an index, indices, lists, inventories or other such information for records responsive to requests herein, whether such index, indices, lists, inventories or other such information for records responsive herein. RESPONSE TO REQUEST FOR PRODUCTION NO. 51: See General Objections. Abex further objects to this request to the extent to which it purports to seek information that has been gathered, or prepared in the course of litigation, or which is otherwise subject to the attorney-client privilege, the attorney work-product doctrine, the rule protecting materials prepared in anticipation of and/or in connection with litigation, or any other applicable privilege. -49-