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(Deposition of James Tatum) <br />1 MS. TATUM: Late '91. <br />2 A. If we have a date by which we can pin <br />3 down the b eginning of construction on the air <br />4 shaft. <br />5 Q. I think it was about April or May of <br />6 '91? <br />7 A. All right, then I'm going to say we <br />8 were first contacted by Winters in about December <br />9 of ' 90 . <br />10 Q. What was said to you at that point? <br />11 A. That they needed to drill an air shaft, <br />12 that they needed to ventilate under the Rancho <br />13 Escondido on the north of us, and they weren't <br />14 going to b e doing work under our property but the <br />15 shaft was just barely over our line and to tie into <br />16 what they were doing north of us. <br />17 MS. TATUM: Can I show him <br />18 something for a minute? <br />19 Q. Sure, what are you showing? <br />20 A. April 2nd letter that we sent. <br />21 Q. When Carl Winters explained to you what <br />22 the compan y wanted to do, what was your response? <br />23 A. Well, initially he wanted to cut into <br />24 us from th e west and construct a power line <br />25 completely across the breadth of our property to <br />37 <br />MEEK & ASSOCIATES <br />3016 3rd Ave., Pueblo, Co 81008 (719) 542-1010 <br />