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M. It is anticipated you may object to a particular interrogatory as vague or <br /> burdensome.Defendants cannot always determine in advance which interrogatories might <br /> truly be burdensome to Third-Party Defendant. It is anticipated that you will respond to <br /> all interrogatories to the best of your ability and in good faith, preserving any bona fide <br /> objections if necessary. It is further anticipated that you will attempt to obtain clarification <br /> or delimitation of Defendants'interrogatories from the undersigned(who stands ready and <br /> willing to do so) if the facts of the particular situation so require. <br /> N. Words used in the plural shall also be taken to mean and include the <br /> singular. Words used in the singular shall also be taken to mean and include the plural. <br /> O. The words"and" and"or" shall be construed conjunctively or disjunctively <br /> as necessary to make the request inclusive rather than exclusive. <br /> P. For each interrogatory, please identify: (a) who provided the information <br /> upon which your Response is based;(b)who has personal knowledge of the facts contained <br /> in your Response; and (c) if the answer to part (b) of this instruction is negative, please <br /> identify the source of the information set forth in your Response. <br /> Q. Pursuant to COLO.R.Civ.P. 33(a),these interrogatories are to be answered <br /> separately and fully in writing under oath,unless objected to,in which event the reasons <br /> for objections are to be stated in lieu of an answer. In answering, each interrogatory set <br /> forth herein shall be recited in full with your response to be placed appearing immediately <br /> thereunder.The answers are to be signed by the person(s)making them and the objections <br /> signed by the attorneys) making them. <br /> DERMTIONS <br /> Unless otherwise indicated, the following definitions shall apply to these <br /> interrogatories: <br /> A. "Coal Basin" refers to that geographic area, approximately four miles west <br /> of the village of Redstone, Pitkin County, Colorado, T. 10 S., R. 89 W., 6ffi P.M., in which <br /> MCR conducted underground coal mining operations from 1956 until 1991.The same being <br /> the area depicted on the attached segment of the USGS Quad-Sheet Placita,Colo. segment <br /> (1963, photorevised 1987). <br /> B. "Coal Preparation Plant" means that former operational facility in Coal Basin <br /> used by MCR to remove impurities from mined coal located in the Sw%4Sw%4 of Section 11, <br /> T. 10 S., R. 89 W., 6`h P.M, and indicated by the call-out "Coal Preparation Plant" on the <br /> L\1TL\L INTERROGATORIES <br /> CIVIL No.97 Cv 131-3 -5- PROPOUNDED TO DMG BY MCR <br />