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INSTRUCTIONS <br /> The following instructions are applicable: <br /> A. These requests are limited to information and documents generated, prepared or <br /> received since January 1, 1980. <br /> B. If any documents cannot be produced in full, produce to the extent possible, <br /> specifying the reasons for your inability to produce the remainder and stating whatever - <br /> information, knowledge or belief you do have concerning the unproduced portion. <br /> C. If any documents requested were at one time in existence but are no longer in <br /> existence, please so state. <br /> D. With respect to each document requested which you do not produce in the grounds <br /> of attorney work product or attorney client privilege, please state the following: <br /> a. The identity of such document, including the name of the author, <br /> addressee, all recipients or distributees, title, type (memo, letter, report, etc.) subject matter and <br /> date; <br /> b. The present location of the document; <br /> C. The identity of each person who has been shown the document; and <br /> d. Each basis in fact and law for withholding such document. <br /> LNTERROGATORIES <br /> INTERROGATORY NO. 1: Identify each person answering or assisting in answering <br /> each of these discovery requests. <br /> INTERROGATORY NO. 2: In DMG's "Third-Party Defendant's Answers to Initial <br /> Interrogatories Propounded to Third-Party Defendant by Defendants," dated approximately March <br /> 12, 1998, DMG at page two objected to MCR's definition of "Reclamation Plan." Identify each <br /> document that you contend is a part of the "Reclamation Plan." <br /> INTERROGATORY NO. 3: Do you contend that the entire multi-volume set entitled <br /> "Coal Basin Mine Permit Renewal Application" forms part of the Reclamation Plan? If not, <br /> identify by chapter, section, appendix or other appropriate label, those parts of the Application <br /> which you contend form a part of the "Reclamation Plan." <br />