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REQUEST FOR PRODUCTION OF DOCUMENTS <br />1. Produce each and every document identified by third -party plaintiffs in third -party <br />plaintiffs' response to the foregoing interrogatories. <br />RESPONSE NO. 1: Such documents will be produced upon reasonable notice at the <br />office of Robert Delaney, 1001 Grand Avenue, Suite 106, Glenwood Springs, Colorado. <br />2. Produce any reclamation plan that was submitted to the bankruptcy court in <br />conjunction with MCR's bankruptcy proceeding. <br />RESPONSE NO. 2: The Debtor's Second Amended Plan of Liquidation, which was <br />approved by the Bankruptcy Court, and for which MLRB and DMG voted, specifically defines <br />the Reclamation Plan at ¶ 1.32 as meaning MLRB permit C -81 -017, submitted as required by the <br />Colorado Mined Land Reclamation Act, C.R.S. Title 34, Article 33. This document was thus <br />incorporated by reference. • <br />3. Produce any work plan followed or used in conducting the reclamation and/or <br />remediation work alleged in paragraphs 18 and 21 of the Amended Third -Party Complaint to <br />have been done by MCR and/or M &E. <br />RESPONSE NO. 3: The Reclamation Plan; DMG already has a copy. DMG approved <br />and monitored all work performed, and reviewed technical and minor revisions, hydrological <br />calculations and designs. See DMG files in Grand Junction. <br />REQUESTS FOR ADMISSION <br />1. Admit that a reclamation plan was not submitted to the bankruptcy court which <br />presided over MCR's bankruptcy proceeding. <br />RESPONSE NO. 1: Denied. The bankruptcy liquidation plan specifically defines and <br />incorporates the Reclamation Plan approved by the Mined Land Reclamation Board in Permit C- <br />81 -017. <br />Dated this 5th day of April, 1999. <br />12 <br />