attached segment of the USGS Quad-Sheet Placita, Colo. segment (1963, photore%-ised
<br /> 1987).
<br /> C. "DMG"means the Division of Minerals and Geology,Department of Natural
<br /> Resources, State of Colorado. It also includes is predecesor, the Mined Land Reclamation
<br /> Division ("MLRD") of the Colorado Department of Natural Resources.
<br /> D. "DMG Reclamation Accounting' means that report attached to the letter of
<br /> Cheryl Linden,Assistant Attorney General,State of Colorado,dated January 22, 1998,in 37
<br /> partially numbered pages, provided pursuant to paragraph VII.B. of the Court's Case
<br /> Management Order
<br /> E. "Document"means all writings of any kind,including,without limitation,the
<br /> originals and all non-identical copies,whether different from the originals by reason of any
<br /> notation made on such copies or otherwise including,without limitation,correspondence,
<br /> memoranda,notes,diaries,statistics,letters,telegrams,minutes,contracts,reports,studies,
<br /> checks, statements, receipts, returns, summaries,pamphlets,books,interoffice and intra-
<br /> office communications, notations of any conversations (including, without limitation,
<br /> telephone calls,meetings,and other communications),bulletins,printed matter,computer
<br /> printouts,teletypes,telefax,invoices,work sheets,graphic or oral records or representations
<br /> of any kind(including,without limitation,photographs,maps,charts,graphs,microfiche,
<br /> microfilm,videotapes,recordings and motion pictures), electronic, mechanical or electric
<br /> records or representations of any kind(including,without limitation,tapes,cassettes,discs,
<br /> recordings and computer memories),and all drafts,alterations,modifications,changes and
<br /> amendments of any of the foregoing.
<br /> F. "Forest Service' means the United States Forest Service, Department of
<br /> Agriculture.
<br /> G. "Lezvicki Report"means the Evaluation of Coal Basin Reclamation September,
<br /> 1997 prepared by Gregory C. Lewicki, P.E., Denver, Colorado, in six unnumbered letter-
<br /> sized pages and eight unnumbered legal-sized pages, and provided to Third-Party
<br /> Defendant December 9, 1997 pursuant to the Court's Case Management Order.
<br /> H. "MCR" means Mid-Continent Resources, Inc., a Delaware corporation
<br /> formerly doing business in the State of Colorado, and operating the coal mines in Coal
<br /> Basin near the village of Redstone, Pitkin County, Colorado.
<br /> I. "Mid-Term Review"or"Mid-Term Reviezv-1991"means the State of Colorado,
<br /> Department of Natural Resources, Mined Land Reclamation Division "MINING PER.'vIIT-
<br /> COAL", Permit No. C-81-017, dated May 31, 1988 to Mid-Continent Resources, Inc., in 42
<br /> pages,including two pages of summaries and trnsmittal letter to Mid-Continent Resources,
<br /> INITIAL INTERROGATORIES
<br /> CIVIL No.97 cv 131-3 -6- PROPOUNDED TO DMG BY MCR
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