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Joel W. Cantrick <br /> Page 5 <br /> relates to issues in this case, specifically establishing the <br /> relationship between the defendants and these corporations. The <br /> Plaintiff request that the defendants provide this information as <br /> it relates to Minerals and Resources. <br /> Interrogatory 48: The information requested by this <br /> interrogatory particularly as it relates to Resources and <br /> Minerals is relevant to issues in this case and is reasonably <br /> calculated to admissible evidence. Therefore, the defendants <br /> should provide this information as it relates to Resources and <br /> Minerals. <br /> Interrogatory 49: The compensation and benefits received by <br /> the defendants from Minerals and Resources are particularly <br /> relevant to issues in this case, and the interrogatory is <br /> reasonably calculated to lead to admissible evidence. <br /> Specifically, this information goes to defining the relationship <br /> between the defendants and the two corporations. The Plaintiff <br /> requests that the defendants provide this information as it <br /> pertains to the defendants and Minerals and Resources. <br /> Interrogatories 50, 51 and 52 : The extension of credit or <br /> guarantee of credit between officers/directors of Minerals and <br /> Resources to these companies is relevant to the relationship <br /> between the two corporations, and the interrogatories are <br /> reasonably calculated to lead to admissible evidence. <br /> In addition, credit or guarantee of credit between officers, <br /> directors, or employees of Minerals or Resources (specifically <br /> any of the defendants) to officers, directors, or employees of <br /> the other corporation is relevant to establishing the <br /> relationship between the two corporations and between the <br /> officer, director, or employee and the particular corporation. <br /> Accordingly, the Plaintiff requests that the defendants provide <br /> this information as it relates to Minerals and Resources and the <br /> defendants. <br /> Interrogatory 53 : The financial records and the <br /> administrative offices of both Resources and Minerals are <br /> directly related to issues pending in this case, and this <br /> interrogatory is reasonably calculated to lead to admissible <br /> evidence. The Plaintiff requests that the defendants provide <br /> this information as it pertains to Resources and Minerals. <br /> II. Request for Production of Documents as to individual <br /> defendants <br />