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Joel W. Cantrick <br /> Page 6 <br /> Request No. 1: The requested documents go to issues in this <br /> case, particularly the relationship between Resources and the <br /> defendants as officers, employees, and independent contractors of <br /> Resources. The Plaintiff requests that the defendants produce <br /> these documents as they pertain to the defendants and Resources <br /> since 1981. <br /> Request No. 2 : The documents requested pertain to the <br /> relationship between Minerals and its officers, employees, and <br /> independent contractors. Considering that the defendants are <br /> involved in both Resources and Minerals, the Plaintiff requests <br /> that the defendants produce these documents as they pertain to <br /> the defendants and Minerals. <br /> Request No. 3 : These documents are relevant to issues in <br /> this case, particularly to the defendants as officers, employees <br /> or independent contractors of Resources and their employment or <br /> financial relationship with Minerals. As such, the Plaintiff <br /> requests that the defendants produce these documents relating to <br /> the defendants and Minerals since 1981. <br /> Request No. 4 : The documents requested pertain to the <br /> relationship between the individual defendants and Minerals. <br /> Considering that the individual defendants are involved in both <br /> Minerals and Resources, these documents as they relate to the <br /> defendants should be produced. The Plaintiff requests that the <br /> defendants produce any such documents in existence since 1981. <br /> Requests No. 12 through 17: The documents requested are <br /> relevant to issues pending in this case, specifically the <br /> defendants' status as agents of Resources. These requests are <br /> reasonably calculated to lead to the discovery of admissible <br /> evidence. The Plaintiff requests that the defendants produce <br /> these documents. <br /> Request No. 20: This request involves documents which <br /> directly relate to issues in this case, specifically to the <br /> relationship between Minerals and Resources. In an effort to <br /> resolve the defendants' objection, the Plaintiff requests any and <br /> all documents reflecting the parent status of Minerals to <br /> Resources since the time when Resources became a wholly-owned <br /> subsidiary of Minerals. <br /> Requests No. 23 and 24 : The requested documents are <br /> directly relevant to issues in this case, specifically the <br /> defendants' status as agents of Resources. The request is <br /> reasonably calculated to lead to admissible evidence. In an <br /> attempt to resolve the defendants' objection, the Plaintiff <br /> requests that the defendants produce documents from 1981 to <br /> present. <br />