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5. Internal memoranda and notes by WFC employees pertaining to the mining and <br />reclamation plans for the Property, their interactions with the plaintiffs and <br />government employees, and other matters relevant to the allegations of the pleadings. <br />6. WFC's records relating to the facts identified by plaintiffs concerning mining <br />operations alleged to be in violation of applicable law, such as records of the amount <br />of topsoil removed from the Property and similar operational records. <br />7. All records, notes, writings, and correspondence within the custody or control of <br />WFC that are relevant to matters alleged in the pleadings. <br />MATTERS REQUIRED BY RULE 26(a)(1)(C) <br />WFC's Damage Computation is as follows: <br />Greg Lewicki & Associates — Permit Renewal No 6, $76,572 <br />Bond Release SL -12 portion of Contract Labor Irrigation Cost 2010, $35,112 <br />Bond Release SL -12 portion of irrigation diesel pump cost for 2010, $5,987 <br />Bond Release SL -12 portion of electric irrigation pump cost for 2010, $4,519 <br />Fertilizing of Bond Release SL12 in year 2011, $7,400 <br />Total: $129,500, in addition to WFC's attorney's fees and costs incurred in responding to the <br />citizen complaints filed by plaintiffs, in an amount to be established by fee application following <br />judgment. <br />MATTERS REQUIRED BY RULE 26(a)(1)(D) <br />Though not within the scope of Rule 26(a)(1)(D), WFC maintains a reclamation bond with the <br />Division, which is a public document available for inspection and copying at the offices of the <br />Division. <br />Respectfully submitted this 6th day of May, 2011. <br />CARVER SCHWARZ McNAB & BAILEY, LLC <br />Duly executed on ink file <br />Christopher Kamper ( #24629) <br />Craig R. Carver ( #5200) <br />Attorneys for Defendant <br />Filed electronically. See C.R. C.P. 121 § 1 -26 Original in file <br />(00050022.1) 4 <br />