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03/26/99 19:15 FAX 3037962777 BURNS FIGA & WILL IA005/017 <br /> INTERROGATORY NO. 7: Identify each "improvement" described in paragraph 25 of <br /> your Third-Party Complaint, and with respect to each, state the specific post-mining use for <br /> which such improvement is to be used, as alleged in paragraph 26 of your Third-Party <br /> Complaint. <br /> ANSWER NO. 7: MidCon hereby incorporates MCR's answer to interrogatory No_ 4 <br /> submitted to it as MidCon's answer to interrogatory No. 7. <br /> INTERROGATORY NO. 8: Identify all persons who have knowledge or information <br /> about the First Claim for Relief in your Third-Party Complaint and with respect to each, a <br /> summary of such knowledge or information. <br /> ANSWER NO. 8: MidCon objects to this interrogatory as being overly broad, <br /> burdensome, vague, harassing and not reasonably calculated to lead to the discovery of <br /> admissible evidence. Without waiving the objections, MidCon states that persons with <br /> information regarding the first claim for relief include, among others, Robert Delaney, Diane <br /> Delaney, Greg Lewicki, Mike Savage, Steve Renner and other DMG employees. <br /> INTERROGATORY NO. 9: Identify all documents, including surveys, which establish <br /> that the culverts, roads, and improvements referenced in paragraph 25 of your Third-Party <br /> Complaint are actually located on property you own. <br /> ANSWER NO. 9: MidCon hereby incorporates the answer of MCR to interrogatory No. <br /> 6 submitted to MCR as MidCon's answer to interrogatory No. 9- <br /> INTERROGATORY NO. 10: Identify all documents and non-written communications <br /> which support the allegations of paragraph 27 of your Third-Party Complaint_ <br /> ANSWER NO. 10: In correspondence between MidContinent Resources, Inc. and <br /> MidCon Realty, LLC on the one hand and DMG on the other, including letter from Robert <br /> Delaney to Michael Long and Kevin Riordon dated April 22, 1998 and letter from Robert <br /> Delaney to Michael Long dated Rine 22, 1998_ <br /> INTERROGATORY NO. 11: Identify all documents and non-written communications <br /> which support the allegations of paragraph 29 of your Third-Party Complaint. <br /> ANSWER NO. 11: Such documents include the multi volume loose leaf notebook set of <br /> the Coal Basin Mine Permit Application and Renewal and the Plan for the White River National <br /> Forest. <br /> INTERROGATORY NO. 12: Identify all documents and non-written communications <br /> which contain references, discusses or otherwise relates to the "express condition" referenced in <br /> paragraph 49 of MCR's Amended Third-Party Complaint. <br /> 4 <br />