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Page Two To support'her claim that the mining property in question is lode in nature, Plaintiff relied primarily on the testimony of Blair Roberts, a geologist. After studying various maps, geology reports, and after having made an examination of the property on 2 occasions; it was his conclusion that the property contained placer materials orhich would support a placer lo- cation, and veins which would support the lode locations. As to Pilot #1 lode claim, it was his conclusion that there was a lode was based upon the fact that at a depth of 8 to 10 feet below the original surface there is a hard granite rock in place. He also located large blocks of granite which con- tained what he described as "veinlets" of quartz and other po- tentially valuable minerals. On Pilot #2 Mr. Roberts found an out crop of a tabular altered zone in granite. He found crystals of quartz in place in that out cropping. As to Diukunda and Mukunda #2 lode claims his conclusion that there were lodes was based upon the fact that some of the prospect pits "may have reached bedrock in place that could support lode claims". In further support of the lode claims, the Plaintiff introduced testimony from Don Smith, Duane Stoner, and Earl Hicks. Mr. Smith had dug on Pilot #1 in 1365 and 1966, and was fairly familiar with the property. Mr. Stoner is an electrician from Texas who had several hobbies including prospecting for valuable minerals. These lay witnesses each testified that in their opinion the type of mineral deposit on the property would support a lode claim. Defendants are late comers to the property having made their 3 placer locations in 1380. Before making the placer locations,Defendants filed location certificates for lode mining clair.is on the same property. Defendants expert testimony concerning the nature of the mineral deposits came from Kenneth L. Myers, Charles L. Johnson, and Richard Fournier. Mr. Myers testified that he prepared Defendants Exhibit 15, which shows the claims as well as the area described as "the pit". The pit is an excavated area on Pilot No. 1 (or on the Rubeck Placers). Mr. Myers testified that he examined Pilot ~1 and Pilot #2 in some detail, although he had not examined the Mukunda or Mukunda #2 claims. No lodes were found within Pilot #1. There is a pegmatite dike (which is probably the tabular zone described by Blair Roberts) located to the West of Rubeck Placer claims, on Pilot #2 lode claim.