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INTERROGATORY NO. 3: Identify each document which was referred to or relied <br />upon to respond to the above Interrogatory no. 2. <br />ANSWER NO. 3: See response to Interrogatory No. 2, above. <br />INTERROGATORY NO. 4: Identify and describe your knowledge, from any source, <br />of any and all reclamation tasks from July 18, 1994 to present which were to be, or had been <br />performed, by the Division at the Coal Basin mine site. Identify in your response the extent of <br />your knowledge of the reclamation performed or to be performed at the mine site, the source and <br />date of your knowledge including, but not limited to, information from reclamation bids done by <br />the Division for reclamation tasks, communications with the Division and the United States <br />Forest Service, site observations and public files of any state or federal agency. <br />ANSWER NO. 4: Objection to the compound and multi - subpart nature of this question. <br />See report and summary of investigation performed by Greg Lewicki and previously furnished to <br />DMG. See also January 22, 1998 "accounting" from DMG and the February 3, 1998 supplement <br />thereto. Also responsive to this Interrogatory are the pleadings, depositions, exhibits and <br />communications with DMG in connection with the previous lawsuit by DMG against Mid - <br />Continent Minerals, et al., in Pitkin County. Since July 18, 1994, MCR agents have visited the <br />Coal Basin site on many occasions and have observed DMG reclamation in progress or the <br />results thereof. These visits are far too numerous to detail. With respect to reclamation tasks <br />which were to be performed by DMG, see the Reclamation Plan; memo dated May 8, 1998 from <br />Steve Renner to Bob Delaney. <br />DMG bid documents. <br />MVC- MINES -345 <br />Sutey Pile <br />Amendment #1 to MVC -MINES -345 <br />PKA -5 -356 <br />Coal Basin/Sutey Pile <br />Amendment #1 to PKA 5 -356 <br />PKA -5 -359 <br />Coal Basin/Mine 3 Reclamation <br />Amendment #1 to PKA -5 -359 <br />Amendment #2 50 PKA -5 -359 <br />4 <br />