GENERAL56174

• Permit No: C1981013
• IBM Index Class Name: General Documents
• Doc Date: 5/11/1995
• Doc Name: FAX COVER
• From: JIM TATUM & ASSOCIATES
• To: SUSAN MCCAMMON CHARLES SANDBERG
• Permit Index Doc Type: CITIZEN COMPLAINTS
• Media Type: D
• Archive: No

'3IM TRTUM & RSSOCIRTES TEL:~3-995-7191
May 11.95 3:12 No .002 P.07
3. Bob arses, c/o Utnh Fuel Company, Skyline Mines, P.O. Sox
719, Helper, Vtah 84626, telephone [phone]. Mr. Green may be
called by videotape deposition. Hn was employed by Basins
predecessor in interest and dealt with the Tatums regarding the
installation of the vent tan on thoir property. He will testify
that he• did not make an agreement with the Tatums that eaein~s
predecessor in interest would convey water rights to the Tntums in
exchange for the installation of the Pnn. He will further testify
that ha informed the Tatume that ha had no authority to enter into
such an agreement. He may also be asked to authenticate a portion
of the survey notes identified in i VIII-s0 balow•.
a. Raipb Lopes, Basin Resources, Inc., 14300 Highway 12;
Weston, Colorado 81901, telephone [phone]. Mr. Lopez may ba
called to testify that he has never been contacted by Jim Tatum, o~
anyone acting on Mr. Tatum~e behall, to arrange for an exchange of
water between the Maxwell 9 and li Ditches by Mr. Tatum and Basin.
in addition, Basin hereby supplements the description of
expected tnetimony of witnesses previously identified:
i. 8ar1 whits. Benin anticipates that Mr. White will be
called by telephonic or videotape deposition. In addition~to the
matters already identified, Mr. White will taatify that he has
never been contacted by Jim Tatum, or anyone acting on Mr. Tatum~e
behalf, to arrange Por an exchange of water between the Maxwell 9
and 11 Ditches by Mr. Tatum and Basin.
2. Aon Thodpeon. in addition to the matters already
identified, Mr. Thompson will testify that ha has never been
contacted by Jim Tatum, or anyone acting on Mr. Tatum~a behalf, to
arrange for an exchange of vatar between the Maxwell 9 and 11
Ditches by Mr. Tatum and Basin.
3. Larry eannatt. In addition to the matters already
identified, 'Mr. Bennett will testify that ha has Haver been
contacted by Jim Tatum, or anyone acting on Mr. Tatum~s behalf, to
arrange for an exchange of vatar between the Maxwell 9 'and 11
Ditches by Mr. Tatum anfl Basin. Mr. BeMett will also testify as
to the purpose of the vent Pen which •urPaoes on the Tatume'
property. Ha will also tastily about the relationship batww~~can the
Pan and the coal mining operations, including a description( of the
extent of the underground mine and its relationship to curPaos
features.
4. Robin Torte. In addition to the matters already
identified, Mr. Forte ie expected to testify that the June 1, 1988
latter agreement between Jim Tatum and Wyoming Fuel Company had
nothing to do with the placement of the vent Pan. He will also
testify consistent with the matters deearibed in hie letter oP July
26, 1991 to Jim Tatum (copy attached).
2
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