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1- <br />1 <br />• <br />7. For each year beginning January 1, 1968 to the present state the date upon <br />which mining activity on the Respondents' Remainder Property began and when it <br />ceased. <br />ANSWER: The Respondents object to this Interrogatory and the following <br />Interrogatories Nos. 8, 9, and 10 on the grounds and for the reasons stated in the <br />Answer to Interrogatory No. 3 above. In addition, the Respondents state that they <br />have had no obligation to maintain records and in fact, records regarding the dates of <br />mining and the amount of turquoise extracted from Respondents Remainder Property, <br />whether in pounds or dollars, are very few to the extent that they exist at all. <br />Moreover, the Respondents did not know until 1992 that the City intended to <br />condemn their property and have had no reason to maintain records prior to that date <br />in the form requested. Without waiving the foregoing objection, the Respondents <br />state that they have reviewed their records in good faith and have provided herewith <br />all of their records regarding the dates of mining and the amount of turquoise, in <br />pounds or dollars, removed from the Respondents Remainder Property since they <br />acquired the property. Respondents Bad Boys of Cripple Creek Mining Company, Inc., <br />Harriet Snare and David Graham, did not acquire the property until April 1988 and <br />consequently have no information from 1968 to 1988. In 1988, Respondents began <br />mining in April and mined through approximately June 15. David Graham was injured <br />in a mining accident in June of 1988 and all mining activity ceased until May 1989. <br />In 1989, mining began in May and continued continuously through the end of the year. <br />For the years 1990, 1991, 1992, 1993, 1994, 1995 and 1996 mining occurred <br />sporadically year-round. Mining from 1992 through 1995 was minimal because <br />Respondents had no money for excavation purposes. All available funds were diverted <br />to the defense of this action. <br />B. For each year beginning January 1, 1968 to the present state the amount, in <br />pounds, of turquoise removed from the Respondents' Remainder Property. <br />ANSWER: See Answer to Interrogatory No. 7 above. <br />In 1988 approximately 400 pounds was removed <br />In 1989 approximately 1100 pounds <br />In 1990 approximately 1000 pounds <br />In 1991 approximately 1200 pounds <br />In 1992 approximately 400 pounds <br />In 1993 approximately 200 pounds <br />In 1994 approximately 200 pounds <br />In 1995 approximately 200 pounds <br />To date 1996, 1800 pounds. <br />5 <br />