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Joel W. Cantrick <br /> Page 12 <br /> and Minerals relates to issues, in this case. Accordingly, the <br /> Plaintiff again asks that the defendant admit or deny these <br /> requests. <br /> VI. Requests for Production of Documents - Minerals <br /> Request No. 1: In an effort to resolve this matter, the <br /> Plaintiff requests that the defendant produce records concerning <br /> financial or employment agreements between Minerals and any of <br /> the individual defendants. <br /> Request No. 2 : In an effort to resolve this matter, the <br /> Plaintiff requests that the defendant produce the requested <br /> documents which reflect any relationship and/or business <br /> arrangement between Minerals and Resources. <br /> Request No. 3 : In an effort to resolve this matter, the <br /> Plaintiff requests that the defendant produce the requested <br /> documents from 1983 to the present. This request relates to <br /> issues in this case, and is reasonably calculated to lead to the <br /> discovery of admissible evidence. <br /> Request No. 4 : In an attempt to resolve the defendant's <br /> objection, the Plaintiff requests that the defendant produce a <br /> quarterly or yearly accounting of receipts and expenditures that <br /> in any way relate to Resources. <br /> Request No. 5: In an attempt to resolve the defendant's <br /> objection, please produce the requested documents as they pertain <br /> to Resources and the individual defendants. <br /> Request No. 6: In an effort to resolve this matter, please <br /> produce the requested documents as they pertain to the individual <br /> defendants as officers, directors, shareholders, or employees of <br /> Minerals and the individual defendants as officers, directors, <br /> shareholders, or employees of Resources. <br /> Request No. 8 : Given that Sanwa was a major secured <br /> creditor of Resources, documents pertaining to the relationship <br /> between Sanwa and Minerals, and Minerals' involvement in <br /> Resources' bankruptcy proceedings are relevant to this case. The <br /> Plaintiff again requests that the defendant produce these <br /> documents. <br /> Request No. 9: In an effort to resolve this matter, the <br /> Plaintiff requests that the defendant produce the requested <br /> documents as they pertain to distribution from Minerals to <br /> Resources or the individual defendants. <br />