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Joel W. Cantrick <br /> Page 10 <br /> relates to Resources is relevant to issues in this case, and the <br /> interrogatories are reasonably calculated to lead to the <br /> discovery of admissible evidence. Accordingly, in an effort to <br /> resolve the defendant's objection, the Plaintiff requests that <br /> Minerals provide this information as it relates to Minerals and <br /> the individual defendants acting as directors and/or officers of <br /> Minerals and the individual defendants and Resources, e.g. , did <br /> Minerals or the individual defendants acting as directors and/or <br /> officers of Minerals ever extend credit to Resources, or the <br /> individual defendants as officers, directors, or employees of <br /> Resources. <br /> Interrogatory No. 52 : In an effort to resolve the <br /> defendant's objection, the Plaintiff requests the defendant to <br /> provide information as it pertains to the defendants as officers, <br /> directors, or shareholders of Minerals to Resources. This <br /> information is relevant to the issues in this case and the <br /> interrogatory is reasonably calculated to lead to the discovery <br /> of admissible evidence. <br /> Interrogatory No. 53 : In an attempt to resolve the <br /> defendant's objection, the Plaintiff requests that the defendant <br /> provide information concerning its ownership of property that is <br /> in any way related or connected to Resources. <br /> Interrogatory No. 54 : In an attempt to resolve the <br /> defendant's objection, the Plaintiff requests that the defendant <br /> provide the information requested by this interrogatory as it <br /> relates to Minerals' ownership of Resources. <br /> Interrogatory No. 60: This information is relevant <br /> particularly as it pertains to Resources or the individual <br /> defendants. The Plaintiff requests that the defendant provide <br /> the information requested by this interrogatory as it pertains to <br /> the transfer of assets from Minerals to Resources or the <br /> individual defendants. <br /> Interrogatory No. 62 : This information as it pertains to <br /> Minerals' interaction with Resources is relevant to the issues in <br /> this case, particularly Minerals' relationship with Resources and <br /> also considering the commonality of directors and officers of the <br /> two corporations. Thus, in an effort to resolve the defendant's <br /> objection, the Plaintiff requests that the defendant provide the <br /> information requested as it pertains to Resources. <br /> Interrogatories Nos. 64 and 65: Any relationship between <br /> Resources and Minerals is relevant to the issues of this case. <br /> Given that Sanwa was the major secured creditor of Resources in <br /> Resources' bankruptcy case, any connection between Minerals and <br /> Sanwa is relevant, and the interrogatories are reasonably <br /> calculated to lead to the discovery of admissible evidence. <br />