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S. "Refuse" means reject material from the Coal Preparation Plant."Refuse pile" <br /> means, by name or location, a stockpile of such reject material. <br /> T. "USGS Quad Sheet Placita, Colo. segment" is the attached portion of the <br /> Quandragle(Map)Sheet,identified as"PLACITA,COLO.39107-B3-TF-024,1963,Photorevised <br /> 1987, DMA 4562 III NE-SERIES V877" the original of which was prepared, printed and <br /> published by the United States Geological Survey, U.S. Department of the Interior, with <br /> call-outs and identifications added by MCR. <br /> U. "You," "your,' "Division," and "Division of Minerals and Geologyi ', unless <br /> otherwise indicated means the Third-Party Defendant, all alter egos and other executive <br /> branch agencies, boards or statutory entities of the State of Colorado, each merged, <br /> consolidated or redesignated predecessor or successor, parent, subsidiary, division, and <br /> affiliate,and each past and present officer,director,official,employee,agent, servant,and <br /> representative of each such entity, and each past and present attorney of each such entity. <br /> INTERROGATORIES <br /> 1. In 1994 DMG took over reclamation work in Coal Basin. Please state all <br /> reasons, the authority, and why and by whom such decision(s) were made. Are there <br /> documents relating to this decision and its process? If so, please attach a copy of such <br /> documents to your responses to these interrogatories or state the circumstances under <br /> which these documents may be inspected and/or copied. <br /> Lewicki Report <br /> 2. Referring to the Lewicki Report, do you agree that tasks numbered 1 <br /> through 19, inclusive, together with the "indirect costs" accurately describe the cost <br /> categories set forth in the MLRB Reclamation Bond?If not,please explain any differences. <br /> 3. Do you agree that the column entitled"1991 Bond Estimate" accurately sets <br /> forth the cost allocations with an aggregate total of $2,992,963 set forth in the MLRB <br /> Reclamation Bond? If not, please explain any differences. <br /> 4. Do you agree that the cost allocation under the column entitled"MCR work" <br /> is equal to or less than the allocated value of such work under the MLRB Reclamation <br /> Bond? If not, please explain any differences. <br /> 5. Do you agree that the amount set forth in the column entitled"King Work" <br /> is equal to or less than the allocated value of such work to be performed by the salvage <br /> INITIAL L\'TERROGATORIES <br /> CIVIL No.97 cV 131-3 -8- PROPOU.\DED TO DMG BY MCR <br />