Document rBd1Rj4agnGn0vGrNeEwxxpjr

information contamed m all the records and documents that might be responsive to this interrogatory The available information, from which Abex would prepare a response to this interrogatory, is contamed m files and records maintained by Abex. To prepare a response to this interrogatory would necessitate the preparation or the making of a compilation, abstract, audit, or 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 150 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, details of which are as follows 1. Winchester quality control 2. Production plans. 3 Subject files, Friction products division 4. Blueprints, Friction products division 5 General 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 mamtained in the ordinary course ofbusiness, should plaintiffs decide to inspect them t -171-