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<br /> Joel C. Cantrick
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<br /> time Resources applied for its permit . " However, in response to
<br /> Request for Admission 2, Robert Delaney admits that he has
<br /> "represented" Resources in front of the Board, but Diane Delaney
<br /> and John Reeves deny that they have done so.
<br /> If the Defendants are attempting to make some sort of
<br /> distinction between "appearing" and "representing, " then they
<br /> have misread the interrogatory. Interrogatory No. 12 asks
<br /> whether the Defendants have "represented" Resources in front of
<br /> the Board. Please clarify the Defendants, position on this
<br /> issue as soon as possible, but no later than March 17, 1995 .
<br /> In addition, please identify the person referred to as "I"
<br /> on pages 3 and 10 of your supplemental responses .
<br /> Pursuant to Judge Jones, ruling and in light of the
<br /> continued tight schedule of this case, please provide responses
<br /> to the following interrogatories, requests for production of
<br /> documents, and requests for admissions by March 17, 1995 . We
<br /> would like to review the requested documents on March 20, 21, and
<br /> 22, 1995 . Please inform me of the time and place in which we can
<br /> inspect the documents on these dates . References to "individual
<br /> defendants" means John A. Reeves, Diane Delaney, and Robert
<br /> Delaney.
<br /> I . Individual Defendants
<br /> Please respond, and produce all documents related thereto,
<br /> to interrogatory nos . 5 (a) , 6 (d) , 7, 14 , 25, 34, 35, 36, 37, 39,
<br /> 40, 48 , 49, 50, 51, 52, as they pertain to the individual
<br /> defendants, Mid-Continent Resources and Mid-Continent Minerals;
<br /> to the extent that the individual defendants, records show and to
<br /> the extent of their knowledge, interrogatory nos . 11, 12 , 13 , 21,
<br /> 29, 30 ; interrogatory nos . 28 , 32, 33 , and 38, to the extent that
<br /> they show the relationship between Resources and Minerals;
<br /> interrogatory no. 26 and interrogatory no. 27 (in your fax of
<br /> February 21, 1995, you stated you would respond to Interrogatory
<br /> No. 27, but failed to do so in your supplemental response) .
<br /> Request for Production of documents Nos . 1, 2, 3 , 4 , 23 , 24 ,
<br /> 25, 26, 27, 28, 29, 30 , 32 , 34, 35, as the requests apply to the
<br /> individual defendants, Minerals and Resources .
<br /> Requests for Admission No. 17 . In your February 21, 1995,
<br /> letter you stated that you would admit or deny this request . In
<br /> your supplemental responses, you have failed to do so.
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