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03/26/99 19:16 FAX 3037962777 BURNS FIGA & WILL Z 006/017 <br /> ANSWER NO. 12: Such docuuments will be made available upon reasonable notice for <br /> inspection at the office of Robert Delaney and in particular, include the contracts for sale of the <br /> property. <br /> REQUEST FOR PRODUCTION OF DOCUMENTS <br /> 1. Produce each and every document identified in response to the foregoing <br /> interrogatories. <br /> RESPONSE NO. 1: The documents (except the multi volume set of loose leaf <br /> notebooks submitted as part of the Coal Basin Permit Application and Renewal Application <br /> already in the possession of Pitkin County and the White River National Forest Plan) will be <br /> made available for inspection upon reasonable notice at the offices of Robert Delaney, 1001 <br /> Grand Avenue, Suite 106, Glenwood Springs, Colorado 81602. <br /> 2 Produce each and every document or other tangible thing you intend to introduce <br /> as an exhibit at trial of this action in support of your First Claim for Relief in your Third-Party <br /> Complaint. <br /> RESPONSE NO. 2: MidCon objects to this request as being overly broad, vague and <br /> premature. The pre-trial procedures under the Colorado Rules of Civil Procedure provide for <br /> disclosure of such information. Because the trial date has not even been set, MidCon has not <br /> determined what documents it will submit as exhibits in a trial. <br /> Dated this 26th day of March, 1999. <br /> Undersigned counsel for MidCon Realty, LLC and Louis M. LaGiglia Creditors' Trustee <br /> under Bankruptcy Plan of Liquidation executes these interrogatories and answers thereto as to <br /> objections only. <br /> BURNS, FIGA& WILL, P.C. <br /> %i <br /> �e . Altiderson (914907) <br /> Plaza Tow ne. Suite 1030 <br /> 6400 S. Fiddlers Green Circle <br /> Englewood, CO 80111 <br /> Telephone: (303) 796-2626 <br /> 5 <br />