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Fax:3038663558 Feb 8 '99 10:08 P.05 <br /> 04r05t99 18:04 FAX 3037962777 BURNS FICA & WILL (�004 <br /> The t3ollowing inSU[wal0 ate applicable: <br /> A. Tb= reqUCStS axe limited to tdbM=twn and doh gea-m=ted, prepared or <br /> received vince JXM Mty 1, 1980. <br /> B. If any documwats cannot be produced in WE, produce to the extent possible, <br /> Specifying the reasons for your inability to produce tha rcmainder and stating wha1+e1 <br /> Wo mafton, knowledge or beli+cf you do have concerning the uupzodwed portion. <br /> C. If aziy documents requested were at one time is existeuoe but are no longer is <br /> existence, phase so state. <br /> D. With respect to each document requested which you do not produce in tie grounds <br /> of attorney work product or attorney client privilege, please state the following: <br /> A. The identity of such document, it-114ng The InHM Of dw author, <br /> addressee, all recipients or auiburees, title, type (memo, letter, report, etx---) subject matter axed <br /> dace; <br /> b. The present location of the documcm; <br /> C. The identity of each person who has been sbown fhe document; and <br /> d. Each basis m fact and law for withbo1dwS sueb do e_ <br /> IlN FUKgOgATg1UM <br /> I1y'i' RROGA'X'M Y'NO. IL Jamury each person, awwaft or assisting in anew aiAg <br /> each of these discovery regents. <br /> RRO YQ 2: In DMG's "Third-Party Defendant's Answers to Initial <br /> Lammogatories P rMounded to Thnd-Party Defendant by Defendam," dated approximately March <br /> 12, 1998, DMCx at page two objected to MCR's deftitloa of"Reclamation Plan." Iderdify each <br /> do=nem that you con teaaod is a part of the "RecIatnation plan." <br /> INIF.RRU A'I'ORY NO, 3: Do you contend that the entire multi-volume set entitled <br /> "Coal Basin Mine Permit Renewal Application" fortes part of the Reclamation Plan? If not, <br /> identify by cbaptcr, section, appendix or other appropriate label, those pares of the Application <br /> which you"umod form A part of the -F.eolamation Plan." <br /> 3 <br />