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Joel W. Cantrick <br /> Page 7 <br /> Request No. 25: Documents showing ownership of, Minerals and <br /> Resources is relevant to the case at hand, and the request is <br /> reasonably calculated to lead to admissible evidence. The <br /> Plaintiff requests that the defendants produce these documents as <br /> they relate to Minerals and Resources. <br /> Requests Nos. 26 through 29: The documents requested <br /> pertain to the relationship between the defendants and Resources, <br /> and the defendants and Minerals. The requests are reasonably <br /> calculated to lead to admissible evidence. Therefore, the <br /> Plaintiff requests that the defendants produce these documents as <br /> they pertain to the defendants, Resources and Minerals. <br /> Request No. 30: In light of the defendants' objection, the <br /> Plaintiff requests that the defendants produce documents as they <br /> pertain to the extension of credit from any of the defendants to <br /> Resources and/or Minerals. These documents are relevant to <br /> issues in this case and the request is reasonably calculated to <br /> lead to the discovery of admissible evidence. <br /> Request No. 32 : In an attempt to resolve the defendants' <br /> objection, The Plaintiff requests that the defendants produce the <br /> requested documents as they pertain to extension of credit from <br /> Resources and/or Minerals to any of the defendants. <br /> This request is relevant to issues in this case, and is <br /> reasonably calculated to lead to the discovery of admissible <br /> evidence. <br /> III. Requests for Admissions as to the individual defendants <br /> Request No. 2 : This request directly relates to issues in <br /> this case, and is reasonably calculated to lead to the discovery <br /> of admissible evidence. In an attempt to resolve the defendants' <br /> objection, the Plaintiff requests that the defendants admit that <br /> they represented Resources before the Mined Land Reclamation <br /> Board concerning Resources' mining operation from 1983 , when <br /> Resources' permit was issued, to present. <br /> Request No. 3 : The defendants object to the phrase <br /> "participated in" Resources' permit application, asserting that <br /> such phrase is vague. The Plaintiff is simply requesting that <br /> the defendants admit that they were involved in assembling the <br /> permit application of Resources and/or submitting it to the <br /> Division of Minerals and Geology. The Plaintiff again requests <br /> that the defendants admit or deny the same. (To clarify, the <br /> defendants are correct that the permit application was not filed <br /> in 1983 . This date should read 1981) . <br /> Request No. 5: Contrary to the defendants' objection, this <br /> request does refer to a specific permit - Resources' mining <br />