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04/05/99 17:30 FAX 3037962777 BURNS FIGA & WILL [1019 <br />INTERROGATORIES <br />INTERROGATORY NO. 1: Identify each person who has participated, assisted or was <br />consulted with in answering or responding to or preparing the answers or responses to these <br />discovery requests, and indicate the specific answer or response on which the person <br />participated, assisted or was consulted with. <br />ANSWER NO. 1: Robert Delaney, Diane Delaney and Geoffrey P. Anderson as to all <br />questions. Mike Savage as to Interrogatories No. 6, 9, 10, 11, 12, 13, 14. <br />INTERROGATORY NO. 2: State whether the property which is the subject of <br />paragraph 24 of the LLC's complaint will remain in the ownership of the LLC and/or whether the <br />LLC has any plan to dispose of such property or to enter discussions and/or negotiations about <br />disposing of the property, including discussions and/or negotiations with the United States Forest <br />Service. <br />ANSWER NO. 2: Objection. Irrelevant and not reasonably calculated to lead to he <br />discovery of admissible evidence. The intention of MidCon is set forth in a letter to Kevin <br />Riordan dated March 2, 1999, a copy of which has been previously disclosed_ If the property is <br />not acquired by the Forest Service then it is anticipated that it will be offered for sale to other <br />prospective buyers. No negotiations are pending with any other prospective buyer. <br />INTERROGATORY NO. 3: State whether the LLC's "desire" to use the improvements <br />as alleged in paragraph 26 of the LLC's complaint is the LLC's final decision (i.e., not subject to <br />change during the time that reclamation is being completed by the Division) regarding whether <br />the improvements will remain at the mine site <br />ANSWER NO. 3: No changes are anticipated on the decision of MidCon to retain <br />ownership of the property pending completion of reclamation by DMG. A transfer of the real <br />property by MidCon to the Forest Service or other third party will obviously moot this issue with <br />respect to MidCon's desires. <br />INTERROGATORY NO. 4: Identify the date on which the LLC was formed and/or <br />able to conduct business as an LLC. <br />ANSWER NO. 4: MidCon's date of organization is May 12, 1998. <br />INTERROGATORY NO. 5: Identify the date on which the LLC entered into the <br />agreement to acquire title, and the date it actually acquired title, to the property described in <br />paragraph 24 of the LLC's complaint. <br />3 <br />