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1998-03-12_GENERAL DOCUMENTS - C1981017 (2)
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1998-03-12_GENERAL DOCUMENTS - C1981017 (2)
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Last modified
3/6/2021 10:02:10 AM
Creation date
5/2/2012 2:24:21 PM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981017
IBM Index Class Name
GENERAL DOCUMENTS
Doc Date
3/12/1998
Doc Name
3rd party defendant's answers to initial interrogatories
From
US Dristict Court
To
Mid-Continent Resources Inc. & DMG
Permit Index Doc Type
General Correspondence
Media Type
D
Archive
No
Tags
DRMS Re-OCR
Description:
Signifies Re-OCR Process Performed
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of such documents to your responses to these interrogatories <br />or state the circumstances under which these documents may be <br />inspected and /or copied. <br />Response: The seed bid is in addition to various <br />project revegetation costs. <br />The Division is unsure as to which costs you are <br />referring in the second part of this interrogatory. Questions <br />regarding revegetation components and costs have been <br />previously answered. Please see responses to interrogatories <br />29, 30, 39 and 48. <br />Documents pertaining to this interrogatory will be made <br />available for inspection at a mutually convenient time at the <br />Division's offices in Denver and \or Grand Junction. <br />50. If we read the DMG Reclamation Accounting <br />correctly, it appears that all costs for revegetation <br />(including tree purchase and plant) adds up to $457,000. Yet <br />the costs per acre to perform this work is significantly <br />higher. Would you please explain this discrepancy? Are there <br />documents relating to these costs? If so, please attach a copy <br />of such documents to your responses to these interrogatories <br />or state the circumstances under which these documents may be <br />inspected and /or copied. <br />Response: Objection: This interrogatory is unclear and <br />vague. It is unclear how the Defendants arrived at the sum of <br />$457,000 or what that figure specifically includes. <br />Consequently, the Division is unable to respond to this <br />interrogatory. <br />51. In connection with "soil analysis" costs contained <br />in the DMG Reclamation Accounting, please explain and identify <br />the areas of this sampling. Are there documents relating to <br />these costs? If so, please attach a copy of such documents to <br />your responses to these interrogatories or state the <br />circumstances under which these documents may be inspected <br />and /or copied. <br />Response: Representative soil samples will be obtained <br />from materials intended to be utilized as a growth medium. <br />Specific sites for obtaining soil samples have not been <br />finally identified. However, remaining topsoil stockpiles, <br />30 <br />
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