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production of coal, coal preparation, and sales of coal at Coal <br /> Basin. After the mine closed, I was actively involved in attempted <br /> sale of mine and reclamation of mine . <br /> RESPONSE AS TO ROBERT DELANEY: b. See answer to Interrogatories <br /> 3 , 4 , and 5 above . <br /> Companies are not conducting mining operations . <br /> Resources, mine closed in January, 1991; undersigned actively <br /> participated in efforts to sell the same, consulted with attorneys <br /> and others employed for that purpose; has actively participated in <br /> efforts to secure reclamation of the mine properties, and the sale <br /> of the same . <br /> RESPONSE AS TO DIANE DELANEY: b. Assist the company in <br /> communications with regulatory agencies, the legislature and the <br /> press . To the extent possible, assist the company in being aware of <br /> regulatory requirements . <br /> C . The length of time you have held the position, job, or <br /> office; <br /> RESPONSE AS TO JOHN REEVES: I have been president of Mid Continent <br /> Resources since about 1973 . Prior to that date I was executive vice <br /> president-coal . For other entities, see response to Interrogatory <br /> 5 . <br /> RESPONSE AS TO ROBERT DELANEY: C . See answers to Interrogatories <br /> 3 , 4 and 5 above . <br /> RESPONSE AS TO DIANE DELANEY: C . Since December 1979 . <br /> d. The amount of any money, compensation, or benefit you <br /> receive in connection with the job, position, or office, including <br /> stock ownership, expense accounts, pension, profit sharing, <br /> retirement plan, and insurance coverage including coverage for <br /> health benefits and for personal liability of any kind including <br /> liability for the debts or obligations of the company. <br /> e . Any task you perform on behalf of the company, regardless <br /> of compensation. <br /> OBJECTION: The defendants object to subsections d and e . With <br /> regard to subsection d, the defendants incorporate their objections <br /> to Interrogatory 3 . Requests about compensation are not relevant to <br /> the issues in this case, nor are they reasonably calculated to- lead <br /> to the discovery of admissible evidence . <br /> With regard to subsection e, it is repetitive of the subpart b, <br /> and therefore, the defendants will not respond to it . <br /> - 11 - <br />