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If defendants cannot answer any interrogatory or request in full, answer to the extent <br /> possible, explain why defendants cannot answer the remainder, and state the nature of the <br /> information or knowledge that defendants cannot answer. <br /> These interrogatories and requests are submitted for the purpose of discovery, and are not <br /> to be taken as waiving any objections which may be made at the trial to the introduction of <br /> evidence on subjects covered by these interrogatories and requests, or as an admission at the trial <br /> of the relevance or materiality of any of the matters covered by said interrogatories and requests. <br /> WRITTEN INTERROGATORIES <br /> 1. Identify each person who has participated, assisted or was consulted with in answering <br /> or responding to or preparing the answers or responses to these discovery requests, and indicate <br /> the specific answer or response on which the person participated, assisted or was consulted with. <br /> 2. State the basis for defendants' allegation, pleading, statement,belief, or contention in <br /> the Defendants' Amended Answer and Counterclaims (no. 88)that the defendants believe that M <br /> & E\King salvage-scrapping remediation work will conclude in 1997. Include in your response <br /> work that M&E\King has performed at the site and any work M&E\King has not completed at <br /> MCR's mine site and at the Carbondale load-out facility which is required to be done by <br /> M&E\King by its bankruptcy court-approved contract. <br /> 3. Identify any and all documents which were referred to or relied upon to support the <br /> allegation, pleading, statement, belief, or contention, and the basis therefor, that M&E\King <br /> salvage-scrapping remediation work will conclude in 1997. <br /> 8 <br />