1999-04-06_GENERAL DOCUMENTS - C1981017 ‎(2)‎

• Permit No: C1981017
• IBM Index Class Name: GENERAL DOCUMENTS
• Doc Date: 4/6/1999
• Doc Name: Response to DMG's interrogatories
• From: US District Court
• To: Mid-Continent Resources, Inc. & DMG
• Permit Index Doc Type: General Correspondence
• Media Type: D
• Archive: No

INTERROGATORIES
INTERROGATORY NO. 1: Identify each person who has participated, assisted or was
consulted with in answering or responding to or preparing the answers or responses to these
discovery requests, and indicate the specific answer or response on which the person
participated, assisted or was consulted with.
ANSWER NO. 1: Robert Delaney, Diane Delaney and Geoffrey P. Anderson as to all
questions. Mike Savage as to Interrogatories No. 6, 9, 10, 11, 12, 13, 14.
INTERROGATORY NO. 2: State whether the property which is the subject of
paragraph 24 of the LLC's complaint will remain in the ownership of the LLC and/or whether the
LLC has any plan to dispose of such property or to enter discussions and/or negotiations about
disposing of the property, including discussions and/or negotiations with the United States Forest
Service.
ANSWER NO. 2: Objection. Irrelevant and not reasonably calculated to lead to the
discovery of admissible evidence. The intention of MidCon is set forth in a letter to Kevin
Riordan dated March 2, 1999, a copy of which has been previously disclosed. If the property is
not acquired by the Forest Service then it is anticipated that it will be offered for sale to other
prospective buyers. No negotiations are pending with any other prospective buyer.
INTERROGATORY NO. 3: State whether the LLC's "desire" to use the improvements
as alleged in paragraph 26 of the LLC's complaint is the LLC's final decision (i.e., not subject to
change during the time that reclamation is being completed by the Division) regarding whether
the improvements will remain at the mine site.
ANSWER NO. 3: No changes are anticipated on the decision of MidCon to retain
ownership of the property pending completion of reclamation by DMG. A transfer of the real
property by MidCon to the Forest Service or other third party will obviously moot this issue with
respect to MidCon's desires.
INTERROGATORY NO. 4: Identify the date on which the LLC was formed and/or
able to conduct business as an LLC.
ANSWER NO. 4: MidCon's date of organization is May 12, 1998.
INTERROGATORY NO. 5: Identify the date on which the LLC entered into the
agreement to acquire title, and the date it actually acquired title, to the property described in
paragraph 24 of the LLC's complaint.
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