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Defendant Western Fuels — Colorado, LLC ( "WFC "), by and through its attorneys, for its <br />Initial Disclosures under Rule 26(a)(1), states as follows. <br />As required by the Rule, these disclosures are made on the basis of the information now <br />known and reasonably available to WFC, notwithstanding that WFC has not completed its <br />investigation of the case and plaintiffs have not yet made their initial disclosures as required by <br />the Rule. If necessary and appropriate, WFC will supplement these disclosures from time to <br />time as further information comes into its possession. <br />MATTERS REQUIRED BY RULE 26(a)(1)(A): <br />Individuals likely to have discoverable information relevant to disputed facts alleged with <br />particularity in the pleadings: <br />1. Employees of WFC (all may be contacted through counsel only) <br />Lance Wade, Mine Manager. Mr. Wade is has knowledge relevant to all matters alleged <br />in the pleadings, including without limitation the performance by all parties of the Coal <br />Mining Lease, WFC's efforts to amend its permits, the content of WFC's permit <br />requirements and WFC's compliance therewith, the content of the complaints certain of <br />the plaintiffs have made with government agencies, the events that occurred and <br />statements that were made by agency personnel during meetings with WFC, WFC's <br />interactions with the Division concerning the mining and reclamation of the Property <br />including any alleged violations of the regulations, the effects of mining reclamation on <br />the subject Property and the schedule of reclamation, the effects of mining on other lands <br />owned by plaintiffs, WFC's employment of certain of the plaintiffs. <br />Murari Shrestha. Director of Engineering and Contracts. Mr. Shrestha has knowledge <br />concerning the negotiation and content of the Coal Mining Lease, including drafts of the <br />document that were circulated and discussed among the parties, and other matters <br />relevant to the allegations of the pleadings. <br />Ross Gubka, Chief Engineer. Mr. Gubka has knowledge relevant to all matters alleged in <br />the pleadings, including without limitation the performance by all parties of the Coal <br />Mining Lease, WFC's efforts to amend its permits, the content of WFC's permit <br />requirements and WFC's compliance therewith, the content of the complaints certain of <br />the plaintiffs have made with government agencies, the events that occurred and <br />statements that were made by agency personnel during meetings with WFC, WFC's <br />interactions with the Division concerning the mining and reclamation of the Property <br />including any alleged violations of the regulations, the effects of mining reclamation on <br />the subject Property and the schedule of reclamation, the effects of mining on other lands <br />owned by plaintiffs, WFC's employment of certain of the plaintiffs. <br />2. Plaintiffs. JoEllen Turner, Michael Morgan, Frank Morgan, and Mary Lou Morgan. <br />(00050022.1) 2 <br />