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Joel W. Cantrick <br /> Page 3 <br /> site. The defendants objected to these interrogatories as •overly <br /> broad and burdensome and stated that the Plaintiff did not <br /> provide a limit on time. The defendants have failed to provide <br /> any response to these interrogatories. <br /> Contrary to the defendant's objection, the interrogatories <br /> request information from the time Resources applied for its <br /> permit, which was in 1981. Consequently, the Plaintiff did <br /> provide a time limit. The Plaintiff requests that the <br /> defendants, to the best of their ability, provide the <br /> information. <br /> Interrogatory 13 : The Plaintiff asks that the defendants <br /> provide the requested information stated in this interrogatory <br /> beginning at the time Resources applied for its mining permit in <br /> 1981. <br /> Interrogatories 15. 16, 17 , 18 and 19: These <br /> interrogatories request information which is directly relevant to <br /> issues concerning this case, particularly the defendants' <br /> relationship with Resources and their status as agents. This <br /> information is reasonably calculated to lead to the discovery of <br /> admissible evidence. Accordingly, the defendants' objections are <br /> unsubstantiated and the defendants should provide the requested <br /> information. <br /> Interrogatory 21: Contrary to the defendants' objection, <br /> the Plaintiff is not asking the defendants to read the Division's <br /> mind about why the Division issued an order to show cause based <br /> on a pattern of violations. Rather, the Plaintiff is requesting <br /> what the defendants' knowledge of the circumstances and <br /> conditions of the site were at the time the Division found <br /> violations - the violations which formed the basis for the <br /> Division's order to show cause why Resources' permit should not <br /> be revoked issued in July 1990. The Plaintiff requests that the <br /> defendants state their knowledge of the conditions of the site <br /> between January 1989 to July 1990. <br /> Interrogatory 24: The reclamation plan to which the <br /> Division is referring is the plan Resources submitted as part of <br /> its permit application. The term "amendment" means permit <br /> revision as that term is defined in section 34-33-103 (18) , C.R.S. <br /> Interrogatory 26: The nature and duration of the <br /> relationship between Resources and Minerals is directly related <br /> to issues concerning Minerals' status as an agent of Resources. <br /> In addition, considering that defendants Robert Delaney and John <br /> Reeves are directors and officers of both corporations, the <br /> requested information is relevant as it pertains to Resources and <br />