1999-03-26_GENERAL DOCUMENTS - C1981017

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03/26/99 19:17 FAX 3037962777 BURNS FIGA & WILL Z 012/017 ANSWER NO. 5: The documents referencing the express condition will be made available for inspection upon reasonable notice at the office of Robert Delaney, 1001 Grand Avenue, Suite 106, Glenwood Springs, Colorado and in particular includes the contracts of sale INTERROGATORY NO. 6: Identify all docrurnents, including surveys, which establish that the culverts, roads, and improvements referenced in paragraph 48 of your Amended Third- Party Complaint are actually located on property currently owned by MidCon Realty, LLC. ANSWER NO. 6: See map entitled "MidCon LLC Land Holdings" dated October 20, 1998 prepared by Greg Lewicki. This map will be available for inspection upon reasonable notice at the office of Robert Delaney. INTERROGATORY NO. 7: Identify each document and any non-w-ritten communications which you contend establish any post-mining use as part of the reclamation plan which is the subject your Amended Third-Party Complaint. ANSWER NO. 7: Such documents include the multi volume Coal Basin Permit and Renewal Application; the White River National Forest Plan (a copy of which is available from the U.S. Forest Service). and correspondence between MCR and the State. Further, DMG left the small metal building at the Prep Plant site, as well as the Lamphouse and the power limes at N4CR's request and proceeded with completion of reclamation in the tunnel portal area where the Lamphouse is located_ Further, the Forest Service recognizes the right of an inholder to have reasonable access to its property_ INTERROGATORY NO. 8: Identify all documents and any non-written communications which relate to the purchase of property by MidCon Realty from you, including any appraisal supporting the value paid for the property or any portion of the property, contracts relating to the purchase, deeds, and correspondence. ANSWER NO. 8: Such documents will be available for inspection upon reasonable notice at the office of Robert Delaney and include, for example, the appraisal dated September 23, 1996, deeds dated June 15, 1998; contract dated June 11, 1998, contract for sale dated May, 8, 1998; promissory notes, deeds of trust and corporate minutes. INTERROGATORY NO. 9: Identify all persons who have knowledge or information about the Fifth Claim for Relief with respect to each, a sumluary of such knowledge or information. ANSWER NO. 9: Objection, vague, overbroad and burdensome. In view of the extensive correspondence and communications, including statements of public meetings, it is impossible to answer this interrogatory. Some of the people who have such information include Robert Delaney,Diane Delaney, Louis LaGiglia, John Reeves, Steven Renner, Anthony Waldron and other personnel at DMG and Pitkin County employees and officials. INTERROGATORY NO. 10: Identify the current officers and directors of Mid- Continent Resources, Inc. 4