Document wg7YbKNBG4X0a0YJXMgD8DOQQ

Abex discontinued the manufacture and sale of asbestos-containing friction products m 1987 and no longer operates any friction product manufacturing facilities There are no current Abex employees, officers who worked for Abex, or directors who sat on its Board during the period Abex manufactured and sold friction products with personal knowledge of the information contamed in 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 125 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 denved, 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, Faction Products Division. -236-