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r <br /> Part 1: Prior to the date of its amended answer filed in this action, it was <br /> represented to MCR and the Creditors' Trustee by the principals of the equipment <br /> liquidating contractor,the joint venture of Machinery&Equipment Co.,Inc.("M&E")and <br /> A. M. King Industries, Inc. ("King"), engaged pursuant to the contract ("M&E,/KItiG <br /> CONTRACT" Answer Exhibit 1) as authorized by the Bankruptcy Court"Order Authorizing <br /> Debtor to Employment Equipment Liquidators and to Obtain Credit Secure by Senior Lien;'entered <br /> August 13, 1992, its work would be completed during the summer and fall of 1997. <br /> Part 2. Coal Basin Mine Site: Other than the building in the Preparation Plant <br /> yard, the water tank tower, the electric power line, and the Rock Tunnels lamphouse, all <br /> equipment and salvage work in Coal Basin under the M&E/KLVG CONTRACT is complete. <br /> MCR and the Creditors' Trustee have requested these items be left for future use. <br /> Part 3. Carbondale Rail Load-out facility: All work at this facility under the <br /> M&E/KING CONTRACT is complete except for minor scrap removal. All office buildings are <br /> excepted from the M&E/King Contract (I I.E.) and all buildings and other industrial <br /> structures at this facility are to remain for post-mining use. <br /> Interrogatory No.3. Identify any and all documents which were referred to or <br /> relied upon to support the allegation,pleading, statement, belief, or contention, and the <br /> basis therefor,that M&E\ICing salvage-scrapping remediation work will conclude in 1997. <br /> Response to Interrogatory No. 3.The M&E/KING CONTRACT identified above. <br /> Interrogatory No. 4. In its accounting, served on defendants on January 23, <br /> 1998, the DMG listed reclamation projects that still need to be performed at MCR's mine <br /> site and at the Carbondale Loadout Facility. With respect to each of the reclamation <br /> projects, state whether defendants believe such project is required under MCR's permit, <br /> and the basis for your answer as to each of the projects. The reclamation projects are as <br /> follows: <br /> a. [1] Roads A,B, C, D, Huntsman <br /> b. [2] Pond Removal <br /> C. [3] Rock Tunnel Vicinity <br /> d. [4] Facilities Area <br /> e. [5] Facilities Area Demolition <br /> f. [6] Mine Bench Outslope Revegetation <br /> g. [7] Mine Maintenance <br /> h. [8] Seed Bid <br /> i. [9] Soil Analysis <br /> j. [10] Tree Purchase and Planting <br /> MCR RFsPONSEs TO <br /> CIVIL No.97 cv 131-3 -3- DMG INITIAL DISCOVERY <br />