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reclamation work to be performed in 1994 at the mine site, contrasted with the subsequent costs <br />incurred by the Division of Minerals and Geology to perform the same work. <br />INTERROGATORY NO. 22: Identify each document which was referred to or relied <br />upon to respond to the above Interrogatory no. 21. <br />ANSWER NO. 22: See response to Interrogatory No. 21, above. <br />INTERROGATORY NO. 23: State the factual and legal basis for the allegations <br />contained in paragraph 44 of the Amended Third -Party Complaint, including each reclamation <br />activity MCR and/or the Trustee alleges was or is a waste of money, and was or is experimental; <br />the areas alleged to have been revegetated more than once; the specific bids that were or are "far <br />higher than [what is] reasonable for the work performed;" the definitions of the terms <br />"experimental" and "reasonable" as those terms are used in paragraph 44; and what MCR and/or <br />the Trustee would consider reasonable for the reclamation tasks include din the allegations of <br />paragraph 44. <br />ANSWER NO. 23: See responses to Interrogatories No. 14, 21 and 22, above. <br />INTERROGATORY NO. 24: Identify each document referred to or relied upon in <br />responding to the above Interrogatory no. 23. <br />ANSWER NO. 24: See response to Interrogatory No. 23, above. <br />INTERROGATORY NO. 25: Identify the real property which will remain private <br />property as alleged in paragraph 47 of the Amended Third -Party Complaint, including who the <br />owner of this property is or will be and whether there is any plan to change ownership of this <br />property, a physical description of where this property is in Coal Basin and what improvements, <br />buildings or culverts as identified in paragraph 48 of the Amended Third -Party Complaint, are <br />located on this private property. <br />ANSWER NO. 25: The real property is that which is currently owned by MidCon <br />Realty, LLC in Coal Basin and is described in the special warranty deed dated June 15, 1998 <br />between Louis M. LaGiglia and Mid - Continent Resources, Inc., grantors and MidCon Realty, <br />LLC, grantee, recorded in the Pitkin County Real Property Records on July 1, 1998, Reception <br />No. 418900. The improvements are described in paragraph 48 of the Amended Third -Party <br />Complaint. See also map entitled "Coal Basin Land Project MidCon, LLC Land Holdings" by <br />Greg Lewicki dated October 20, 1998. The only present plan to change ownership on the <br />MidCon Realty, LLC Coal Basin tract is contained in the letter to Kevin Riordon of the USFS <br />dated March 2, 1999. <br />INTERROGATORY NO. 26: State the factual and/or legal basis for the allegations in <br />paragraph 57 of the Amended Third -Party Complaint that the Division's Huntsman Project "will <br />likely cause extensive sedimentation of the 001 Ponds." Include in your response a description <br />of any site visit or investigation done before, during or after the performance of the Huntsman <br />Project by MCR, the Trustee, or a contractor on behalf of MCR or Trustee that support or refute <br />10 <br />