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<br /> Joel C. Cantrick
<br /> Page 3
<br /> II . Minerals
<br /> Please respond, and produce all documents related thereto,
<br /> to interrogatories nos . 6, 7, and 9 as they relate to Minerals
<br /> and the individual defendants; interrogatory no. 13 as it relates
<br /> to Minerals, Resources, and the individual defendants; please
<br /> respond to interrogatory nos . (without documents) 16, 43 , and 44
<br /> as they relate to the relationship between Resources and
<br /> Minerals; please respond to interrogatories nos . (with documents)
<br /> 36 , 37, 38, 39, 45, 46, 47, 48, as they relate to Minerals and
<br /> the individual defendants; and interrogatory nos . 49, 50, 51, 52 ,
<br /> as they relate to Minerals, Resources, and the defendants .
<br /> Requests for Admissions Nos . 1, 2, 3 , 7, 8, 9, 10, 11, 12,
<br /> 13 , 14 , 16 , 17, 18, 19, 20 .
<br /> Requests for Production of Documents Nos . 3 , 5, 6 , and 9, as
<br /> they relate to the individual defendants.
<br /> We again request that the individual defendants answer
<br /> Interrogatory No. 21 . You stated in your February 21, 1995, that
<br /> you will not respond to this interrogatory because you do not
<br /> know whether we want the defendants' knowledge of mining
<br /> conditions, safety conditions, environmental conditions, etc .
<br /> In another attempt to resolve this matter, please provide us with
<br /> the defendants' knowledge concerning those conditions at
<br /> Resources' site which pertain to the pattern of violations issued
<br /> in July 1990, including environmental conditions, mining
<br /> conditions, and safety conditions for the time period of July
<br /> 1989 to July 1990 .
<br /> Also in your February 21 letter, you state that the
<br /> individual defendants will not answer Interrogatory No. 28
<br /> because it is not limited to independent contractors common to
<br /> Minerals and Resources . Again, in an attempt to resolve this
<br /> issue, please provide this information as it pertains to
<br /> independent contractors common to both Minerals and Resources .
<br /> We look forward to receiving your responses to the discovery
<br /> request on or before March 17, 1994 , as well as your response to
<br /> other issues addressed in this letter. Thank you for your
<br /> attention to this matter.
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