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District Court, County Of Pitkin, State Of Colorado <br /> Case No. 97 CV 13 1-1 <br /> BOARD OF COUNTY COMMISSIONERS' INTERROGATORIES AND REQUESTS <br /> FOR PRODUCTION OF DOCUMENTS DIRECTED TO MID-CONTINENT <br /> RESOURCES, INC.,AND LOUIS M. LAGIGLIA, CREDITORS' TRUSTEE UNDER <br /> BANKRUPTCY PLAN OF LIQUIDATION <br /> Board of County Commissioners of Pitkin County, Colorado, et al. v. Mid-Continent Resources, <br /> Inc., et al. <br /> Page 7 <br /> (d) Identify all persons who sent and all who received the original and copies of <br /> the document affected, or who are involved in the subject matter of the <br /> Interrogatory. <br /> (e) State the subject matter of the document affected. <br /> INTERROGATORIES <br /> 1. Identify each person who answered or assisted in answering or was consulted in <br /> answering each of these discovery requests, and indicate the specified answer or response for <br /> which the person answered, assisted, or was consulted. <br /> 2. Identify each document that you contend is a part of the "Reclamation Plan" which <br /> is the subject of your Amended Third-Party Complaint. <br /> 3. Identify each and every road within Coal Basin which you contend should not be <br /> reclaimed or revegetated for any reason, and with respect to each, state the reason why such roads <br /> should not be reclaimed or revegetated. <br /> 4. Describe each and every improvement, including roads and culverts, referenced in <br /> paragraph 49 of your Amended Third-Party Complaint and with respect to each, the post-mining <br /> uses for which they are desired. <br /> 5. Identify every document and non-written communication which contains, <br /> references, discusses, or otherwise relates to the "express condition" referenced in paragraph 49 of <br /> your Amended Third-Party Complaint. <br /> 6. Identify all documents, including surveys, which establish that the culverts, roads, <br /> and improvements referenced in paragraph 48 of your Amended Third-Party Complaint are actually <br /> located on property currently owned by MidCon Realty, LLC. <br />