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REQUEST FOR PRODUCTION OF DOCUMENTS <br /> General Response to all document production requests: All documents not <br /> heretofore furnished to MCR by the Division are available for inspection at the Division's <br /> Grand Junction and/or Denver Offices during normal business hours, upon reasonable <br /> advance notice and at time(s) and date(s) mutually convenient to the parties. <br /> REQUEST NO. 1: Produce all documents identified in the answers to the above <br /> interrogatories. <br /> Response: With the exception of Memo from Daniel T. Mathews to Steven <br /> Renner, Colorado Division of Minerals and Geology, dated November 23, 1998, regarding <br /> outslope revegetation commitment, which will not be produced on the basis that it falls within <br /> the deliberative process and attorney work product privileges, all other documents pertaining <br /> to each of the interrogatories are available as set forth in the General Response. Please note <br /> that many of these documents have already been furnished to MCR pursuant to its 1998 <br /> Request for Production of Documents. <br /> REQUEST NO. 2: Produce all water and soil sample results from Coal Basin. <br /> Response: See General Response. <br /> REQUEST NO. 3: Produce all documents supporting the third affirmative defense in <br /> your Answer that you have fully and completely complied with the liquidation plan. <br /> Response: See Objection to Interrogatory No. 23. <br /> REQUEST NO. 4: Produce all documents that support your contention in paragraph <br /> 18 of your Answer to Amended Third-Party Complaint that M&E/King did not perform <br /> reclamation work. <br /> Response: See General Response. <br /> REQUEST NO. 5: Produce all documents that have been used, referenced or referred <br /> to,to develop plans, specifications, bid documents, contracts evaluations, assessments, <br /> memoranda, close-out reports, or other reports from revegetation undertaken at Coal Basin by <br /> DMG, OSM or others working under contract to them or under their control. <br /> Response: The documents pertinent to this request are identical to those identified <br /> in response to Interrogatory No. 10. See General Response. <br /> 11 <br />