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In Alliance to End Repression v. Rochford [75 FRD 441, 447 (N.D.Ill. 1977)], the court rejected an objection to discovery requests on the grounds that production of the information would be unduly burdensome because the materials were not in an organized filing system. ¶ The court further concluded that: 'To allow a defendant whose business generates massive records to frustrate discovery by creating an inadequate filing system, and then claiming undue burden, would defeat the purpose of discovery rules.