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NPH. b ":y 3•Jt,P11 U1G.GJCT 1 303 2410336 P.3 <br /> INTERROGATORY NO.2: In DMG's"Third-Party Defendant's Answers to Initial <br /> Interrogatories Propounded to Third-Party Defendant by Defendants,"dated <br /> approximately March 12, 1998, DMG at page two object to MCR's definition of <br /> "Reclamation Plan." Identify each document that you contend is a part of the <br /> "Reclamation Plan." <br /> Response: The reclamation plan is contained in the Coal Basin Mine Permit <br /> Application(January 26, 1981),tlic Coal Basin Mine Permit Renewal Application <br /> (December 1, 1987), all supporting documents prepared or submitted in support of these <br /> applications by Mid-Continent Resources or the Division; all approved Minor,Technical <br /> and Permit Revisions to the plan, ell supporting documents prepared or submitted in <br /> support of any such revisions by Mid-Continent Resources or the Division; and the <br /> Proposed Decision and Findings of Compliance documents prepared by the Division as a <br /> result of approval of Permit or Permit Renewal Applications and Permit Revisions. <br /> The documents which constitute the reclamation plan arc voluminous and arc kept by the <br /> Division in the normal course of its business.These documents will be made available for <br /> inspection during normal business hours, upon reasonable advance notice and at time(s) <br /> and datc(s)mutually convenient to the parties at the Division's office in Grand Junction. <br /> Please note that the documents contained in the Proposed Decision and Findings of <br /> Compliance have been produced and given to MCR and the Trustee pursuant to their 1998 <br /> request for production of documents. <br /> INTERROGATORY NO.3: Do you contend that the entire multi-volume set cYititled <br /> "Coal Basin Mine Permit Renewal Application"forms pare of the Rcclaniation Plan? If not, <br /> identify by chapter,section,appendix or other appropriate label,those parts of the Application <br /> which you contend form a part of the"Reclamation Plan." <br /> Response: Yes. <br /> INTERROGATORY NO.4: identify all documents concerning the 1991 AML Mitte <br /> No. 5 reclamation project in which trees were planted in V-shaped retaining structures, along <br /> with willow cuttings at the bottom of the slope. <br /> Response: The documents concerning this project are located in the Division's <br /> office in Denver in the respective file for this project. The documents are voluminous and are <br /> kept in the regular course of the Division's business. The documents will be made available <br /> for inspection at the Division's officc in Denver upon reasonable advance notice at a time and <br /> date mutually convenient to the panics. <br /> INTERROGATORY NO.3: Identify all documents concerning north slope <br /> rcvegctation efforts below the strip pit, including but not limited to,all specifications, bid <br /> 2 <br />