1999-03-26_GENERAL DOCUMENTS - C1981017

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03/26/99 19:17 FAX 3037962777 BURNS FIGA & WILL 1jh 011/017 INTERI20GATORIE+S INTERROGATORY NO. 1: Identify each person who answered or assisted in answering or was consulted in answering each of these discovery requests, and indicate the specified answer or response for which the person answered, assisted, or was consulted_ ANSWER NO. 1: Robert Delaney, Diane Delaney, Louis M. La Giglia and Geoffrey Anderson as to all Interrogatories. INTERROGATORY NO. 2: Identify each document that you contend is a pan of the "Reclamation Plan" which is the subject of your Amended Third-Party Complaint_ ANSWER NO. 2: The Reclamation Plan includes the multi volume set of loose leaf notebooks submitted as part of the Coal Basin Permit Application and Renewal Application (a copy of which is on file in the Pitkin County Planning and Zoning office), together with all correspondence and other documents approving amendments to the Plan, including all permits, technical, minor and other revisions; also included is the approved bankruptcy plan and all amendments thereto. INTERROGATORY NO. 3: Identify each and every road within Coal Basin which you contend should not be reclaimed or revegetated for any reason, and with respect to each, state the reason why such roads should not be reclaimed or revegetated. ANSWER NO. 3: The roads in Coal Basin should be reclaimed and revegetated pursuant to the Reclamation Plan which provides that the road from the Prep Plant to the Lamphouse and the roads from the Lamphouse from the No. l and No_ 4 Mine sites shall remain open for light duty use and the road surfaces narrowed. Access should be continued to the east portion of the property owned by MidCon Realty, LLC. When MCR transferred property to the Forest Service, the right to use existing roads was preserved. The owners of the Thompson- Willison inholdings have the right to continue to use the roads accessing their property. The road from Redstone to the Prep Plant is outside the permit area and not included in the Reclamation Plan. INTERROGATORY NO. 4: Describe each and every improvement, including roads and culverts, referenced in paragraph 49 of your Amended Third-Party Complaint and with respect to each,the post-mining uses for which they are desired. ANSWER NO. 4: The improvements referred to in paragraph 49 of the Amended Third- Parry Complaint are described in paragraph 48 of the Amended Third-Party Complaint. The use or reason for which they should be retained is for access to the property, for use of the two buildings that are left for recreational purposes and the power line to service the buildings. INTERROGATORY NO. 5: Identify every document and non-written communication which contains, references, discusses, or otherwise relates to the "express condition" referenced in paragraph 49 of your Amended Third-Party Complaint. 3