_GENERAL DOCUMENTS - C1981017 (178)

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matters, reviewing, advising and signing contract documents, as well as other activities generally associated with those offices . RESPONSE AS TO DIANE DELANEY: Refer to response to Interrogatory No. 6 . Interrogatory No. 8 . State your involvement in the application process for Mid-Continent Resources Inc . Is, permit no. C-81-017 issued in 1983 by the Division of Minerals and Geology. Include a full description of your involvement in the application itself and in the determination of the reclamation plan, and identify each and every person with whom you conferred concerning the application and reclamation plan, each and every person who made or participated in decisions for Resources, each and every contact you had with the Division of Minerals and Geology concerning the permit application, a description of the nature of each and every contact, and a list and description of each and every written correspondence done on behalf of Resources concerning the permit application. OBJECTION: The defendants object to this interrogatory on the grounds that it is overly broad and burdensome . The interrogatory requests specific and detailed information about conversations and events that occurred several years ago. Without waiving this objection, the defendant provides the following response : RESPONSE AS TO JOHN REEVES: I had no first hand involvement with the application and the determination of the reclamation plan. It is my recollection that the individuals involved with the determination of the plan were attorney Dave Sturges, George Wear, Doug Bowman, Bill Turnipseed, Diane Delaney and, perhaps, one or two others in the Glenwood Springs office whom I can' t recall . I was not involved in any of the decision making processes pertaining to the plan. I conferred with them pertaining to the status of the plan. It is my recollection that I had no involvement or communications with the Mine Land Reclamation Division or Ecard. The best that I can recall is that George Wear and Dave Sturges met with the MLRD. RESPONSE AS TO ROBERT DELANEY: Participated in decisions to employ personnel performing functions in preparation for mine reclamation plan, including environmental coordinator, Doug Bowman, special projects manager, George Wear, government relations person, Diane Delaney, attorney Dave Sturges, attorney Edward Mulhall, engineer Bill Cheney, and others, whose names are not presently recalled; conferred with the named individuals about different aspects of the reclamation plan; wrote various letters and prepared certain documents as set forth in files produced; conferred with and corresponded with Lucius Woods, of the Attorney General' s office concerning bond forms, surety forms, and trust deeds . Contacts and - 13 -