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GENERAL OBJECTIONS <br /> The Division objects to the Defendants' definition of <br /> "Reclamation Plan. " This definition appears to exclude numerous <br /> requirements of the approved permit issued to Mid-Continent <br /> Resources (MCR) . The Defendants' definition, therefore, does not <br /> accurately describe the requirements of MCR' s permit . The <br /> Division will answer questions related to requirements of the <br /> permit or reclamation plan by citing all portions of MCR' s permit <br /> which set forth requirements mandated by that permit . <br /> The Division also objects to Instruction F to the extent <br /> that it requires the Division to provide home addresses . That <br /> part of the request is not relevant to the issues in this case, <br /> nor is it reasonably calculated to lead to admissible evidence . <br /> INTERROGATORIES <br /> 1 . In 1994 DMG took over reclamation work in Coal <br /> Basin. Please state all reasons, the authority, and why and by <br /> whom such decision (s) were made. Are there documents relating to <br /> this is decision and its process? If so, please attach a copy of <br /> such documents to your responses to these interrogatories or <br /> state the circumstances under which these documents may be <br /> inspected and/or copied. <br /> Response: Michael Long, the Division Director, in <br /> consultation with the Colorado Attorney General' s Office, made <br /> the decision based upon the provisions of the Procurement Code, <br /> 24-101-101, and 24-101-201, et . seq. , and the provisions of the <br /> Colorado Surface Coal Mining Reclamation Act, 34-33-101, C.R.S . , <br /> et . seq. There are documents relating to this decision. Those <br /> documents will be made available for inspection at a mutually <br /> convenient time at the Division' s offices in Grand Junction <br /> and\or Denver. <br /> Lewicki Report <br /> 2 . Referring to the Lewicki Report, do you agree that <br /> tasks numbered 1 through 19, inclusive, together with the <br /> "indirect costs" accurately describe the cost categories set <br /> forth in the MLRB Reclamation Bond? If not, please explain any <br /> differences . <br /> 2 <br />