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<br />c. The address of the United Minerals facility is 280 <br />East. 64th Ave., approximately one block off of Broadway in the <br />north Denver metro area. A photograph of the facility is <br />attached as Attachment C hereto. <br />d. Upon information and belief, the following persons <br />loaded the concentrates into a truck or trucks: <br />Don Clark, mine foreman <br />Gates Hartley, son of Plaintiff <br />Ken Heath, mechanic for Plaintiff <br />Rick Clark, relative of Don Clark <br />e. Upon information and belief, the concentrates were <br />transported to the smelter by truck or trucks by the following <br />persons: Gates Hartley; Ken Heath; and/or Rick Clark. <br />f. Upon information and belief, the concentrates were <br />rendered into the care of the following persons: John O'Malley; <br />Gary Ingram; Marvin Teeter a/k/a Marvin Teter; and/or United <br />Minerals, and leached of their gold content for which settlement <br />was made to Durango Metals, Thames Hartley, or their nominees in <br />the amount of approximately $30,000. <br />g. Upon information and belief, the Plaintiffs paid to the <br />individuals or entity identified in ¶ 1(f) a total of <br />approximately $2,000 for the smelting of the concentrates. <br />3. The named persons are persons known to Plaintiffs, or under <br />Plaintiffs' control. But for the Plaintiffs' active concealment, <br />the information reported above would have been discovered, and <br />routine discovery conducted. Defendant is entit ed to an order <br />allowing discovery of the named pers s, and for the Plaintiffs <br />to produce its employees for depos' i <br />R. <br />FURTHER, THE AFFIANT SAYETH NAUGHT <br />Subscribed under oath before me on this day o „Q~ <br />1996. <br />My Commission expires: a~ ~9~i ~ <br />Notary Public <br />2 <br /> <br />Z <br />i <br />