_GENERAL DOCUMENTS - C1981017 ‎(178)‎

• 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

Joel W. Cantrick
Page 8
permit. The Plaintiff asks that the, defendants admit or deny
that they assisted, helped, or participated in, Resources' permit
renewal application filed in 1987.
Request No. 12: In an attempt to resolve the defendants'
objection, the Plaintiff requests that the defendants admit or
deny that Resources did not make the showing required by the May
22, 1991, Mined Land Reclamation Board order that it could
perform reclamation as set forth in that order.
Request No. 13 : The Plaintiff requests the defendants to
admit or deny that Resources failed to perform the reclamation of
its mine site in accordance with the schedule set forth in the
May 22, 1991, order of the Mined Land Reclamation Board.
Request Nos. 17 and 18: In an attempt to resolve the
defendants' objection, the Plaintiff requests that the defendants
admit or deny that they made decisions, or assisted in decisions,
concerning Resources' compliance with the requirements of the
Colorado Surface Coal Mining Reclamation Act, 34-33-101, et seq.
C.R. S. , concerning Resources' mining operation since 1983 when
the Division of Minerals and Geology issued Resources a mining
permit. This request is directly relevant to the issues in this
case.
In addition, the Plaintiff requests that the defendants
admit or deny that they made, or assisted in the making of,
decisions concerning the finances relating to Resources' mining
operation. Again, this request is directly related to the issues
in this case.
Request No. 19 : The Plaintiff requests that the defendants
admit they participated in revisions or amendments to the
reclamation plan required by the Division of Minerals and Geology
or the Mined Land Reclamation Board, or requested by Resources,
or participated in responding to any such revisions or amendments
since 1983 when Resources was issued a mining permit.
IV. Interrogatories to Minerals
Interrogatories No. 6 and 7: These interrogatories request
information that is pertinent to the organization of Minerals,
and the individual defendants' and Resources' relationship with
Minerals, and are reasonably calculated to lead to the discovery
of admissible evidence. Accordingly, the Plaintiff requests that
Minerals provide this information as it relates to Resources, and
defendants John Reeves, Robert Delaney, and Diane Delaney,
hereinafter called the individual defendants.
Interrogatories Nos. 12 and 13 : In an effort to resolve the