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ANSWER NO. 17: MidCon paid $983,790.00 for the Coal Load Out Facility. <br /> Financing of$1 million was provided by Mid-Continent Coal and Coke Company. <br /> INTERROGATORY NO. 18: Identify all documents and non-written communications <br /> which relate to the purchase of the Coal Load Out Facility by the LLC described in paragraph 42 <br /> of the LLC's complaint including appraisals supporting or refuting the value paid for the property <br /> or any portion of the property, the contract relating to the purchase, deeds and correspondence. <br /> ANSWER NO. 18: All such documents shall be made available for inspection upon <br /> reasonable notice at the office of Robert Delaney, 1001 Grand Avenue, Suite 106, Glenwood <br /> Springs, Colorado. <br /> INTERROGATORY NO. 19: Identify all corporate minutes, internal memoranda, <br /> letters, correspondence, and other documents relating to the decision of the LLC to purchase the <br /> Coal Load Out Facility. <br /> ANSWER NO. 19: All such documents shall be made available for inspection upon <br /> reasonable notice at the office of Robert Delaney, 1001 Grand Avenue, Suite 106, Glenwood <br /> Springs, Colorado. <br /> INTERROGATORY NO. 20: Identify the reclamation tasks which the LLC has <br /> completed, is in the process of completing, or intends to undertake at the Coal Load Out Facility. <br /> Include in your response the cost of each reclamation task that has been, is being, or will be <br /> performed by the LLC at the Coal Load Out Facility. <br /> ANSWER NO. 20: Buildings and structures not required for post-mining uses have <br /> been removed under the A&MXing contract. Buildings not removed have been converted or are <br /> in the process of being converted to post-mining uses. Substantial grading has been done to <br /> improve access, improve drainage and to fill a large cavity on the east end of the Unit Train Load <br /> Out Bin. Substantial revegetation has occurred on the graded areas. Upon completion of <br /> grading, further revegetation is intended. The cost has not been determined. <br /> INTERROGATORY NO. 21: State the factual and/or legal basis for the allegations <br /> contained in paragraph 44 of the LLC's Third-Party Complaint that the LLC requires written <br /> acknowledgement from DMG that reclamation is complete at the Coal Load Out Facility and that <br /> DMG will assert no rights in the Coal Load Out Facility in order for the property to be <br /> marketable. Include in your response under what authority and under what conditions the LLC <br /> alleges it is entitled to require the written acknowledgement from the Division and the specific <br /> basis for the LLC's allegation that without such written acknowledgement, the property would <br /> not be marketable. <br /> ANSWER NO. 21: Objection. Calls for legal conclusions and analysis. <br /> INTERROGATORY NO. 22: Identify all documents referred to or relied upon in <br /> responding to the above Interrogatory no. 21. <br /> 7 <br />