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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 />