Document zbbY2xeoyxoXR65Xg5O0amJ3a

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 100 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 of which are as follows* 1. Research and development, Raw materials. 2. Lab notebooks, Product development 3 Subject files. 4. Engineering test results 5 Formula, testing, and development. 6 Production/testmg research. 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 m Brooklyn, New York, where they are maintained m the ordinary course of business, should plaintiffs decide to mspect them To the extent that any of the documents that plaintiffs decide to mspect were prepared m anticipation of litigation or for tnal 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 -84-