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_GENERAL DOCUMENTS - C1981017 (178)
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_GENERAL DOCUMENTS - C1981017 (178)
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Last modified
11/2/2020 8:40:38 AM
Creation date
10/19/2012 10:19:09 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981017
IBM Index Class Name
GENERAL DOCUMENTS
Doc Name
Bid Documents (IMP) Court Appeals
Permit Index Doc Type
General Correspondence
Media Type
D
Archive
No
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DRMS Re-OCR
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Signifies Re-OCR Process Performed
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Joel W. Cantrick <br /> Page 2 <br /> or compensation they receive, or have received, as a director of <br /> any corporation. <br /> The amount of compensation or payment received by the <br /> defendants as directors of Mid-Continent Resources Inc. <br /> (Resources) is directly relevant to the defendants' status as <br /> agents of that corporation, and this interrogatory is reasonably <br /> calculated to lead to the discovery of admissible evidence. <br /> Accordingly, the Plaintiff demands that the defendants provide <br /> this information as it pertains to Resources. <br /> In addition, since there are common directors to Mid- <br /> Continent Minerals Corporation (Minerals) and Resources, the <br /> amount of compensation or payment to the defendants as directors <br /> of Minerals is also relevant to issues in this case, and the <br /> interrogatory is reasonably calculated to lead to the discovery <br /> of admissible evidence. Accordingly, the Plaintiff requests that <br /> the defendants supply this information. <br /> (It should be noted that on page 9 of the defendants' <br /> response, the date of the incorporation of Redstone Properties is <br /> not given. The Plaintiff requests that the defendants provide <br /> this information) . <br /> Interrogatory 6: : Under 6 (a) and (c) , defendant Robert <br /> Delaney's response is to refer to his responses in <br /> Interrogatories 3, 4 , and 5. However, it is believed that these <br /> latter interrogatories do not completely cover Mr. Delaney's <br /> professional relationship with Resources. The Plaintiff requests <br /> this information. <br /> Under 6 (d) , the defendants object to providing information <br /> concerning money, compensation, or benefits they have received in <br /> connection with a job, office, or position with Resources and <br /> Minerals, among others. This information as it pertains to <br /> Resources and Minerals is relevant to issues in this case, and is <br /> reasonably calculated to lead to the discovery of admissible <br /> evidence. The Plaintiff requests that the defendants provide <br /> this information as it applies to Resources and Minerals. <br /> Interrogatory 7: The defendants again refuse to provide <br /> information concerning compensation or payment for any position, <br /> job, or office they have held with Resources. This information <br /> is directly relevant to the defendants' status as agents of <br /> Resources. Therefore, the defendants must provide this <br /> information. <br /> Interrogatories 11 and 12 : The Plaintiff requested the <br /> times when the defendants represented Resources in meetings or <br /> discussions with the Division of Minerals and Geology or in front <br /> of the Mined Land Reclamation Board regarding Resources' mine <br />
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