Dennis brings a product liability lawsuit against Shanghai Corp. for an injury to his hand sustained in a stamping machine accident. One of Denniss interrogatories requested Shanghai to list all complaints lodged over the last decade concerning safety guards on stamping machines. Shanghai makes more than 25 types of stamping machines and has over 5000 complaints in an unorganized file. How should the interrogatory be addressed?

7. Dennis brings a product liability lawsuit against Shanghai Corp.for an injury to his hand sustained in a stamp- ing machine accident. One of Denniss interrogatories requested Shanghai to list all complaints lodged over the last decade concerning safety guards on stamping machines. Shanghai makes more than 25 types of stamping machines and has over 5000 complaints in an unorganized file. How should the interrogatory be addressed