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g. Specify the dates ( if any) when Minerals made payments <br /> to any creditor( s ) on any extension of credit made to Coal and <br /> Coke ( including loans , installment purchase agreements, open <br /> account, etc . ) . If so, state with respect to each instance the <br /> date of the payment; the amount of the payment; the name( s ) of the <br /> creditor(s ) ; and the name( s ) -of the guarantor(s ) . - - - - <br /> h. Specify the dates ( if any) when Coal and Coke extended <br /> credit ( including loans , installment purchase agreements, open <br /> account, etc . ) or guaranteed the extension of credit to Minerals . <br /> If so, state with respect to each instance the date of extension <br /> of credit; the amount of credit extended; the name( s ) of the <br /> creditor( s ) ; and the name( s ) of the guarantor(s) . <br /> i. Specify the dates ( if any) when Coal and Coke made <br /> payments to any creditor( s ) on any extension of credit made to <br /> Minerals ( including loans , installment purchase agreements , open <br /> account, etc . ) . If so, state with respect to each instance the <br /> date of the payment; the amount of the payment; the name( s ) of the <br /> creditor(s ) ; and the name( s) of the guarantor( s ) . <br /> j . Identify all written agreements that relate to and/or <br /> discuss the circumstances specified above. <br /> k. If any oral agreement currently exists or previously <br /> existed that relates to the circumstances specified above, state <br /> the date when it was made, with what officers , agents , or servants <br /> of Minerals and Coal and Coke it was made-, and what its exact and <br /> complete terms and conditions were . <br /> OBJECTION: See objection to Interrogatory No. 16 . <br /> Interrogatory No. 23. State the full name, residence and <br /> business addresses , and telephone numbers of all of the employees <br /> of Minerals who are or who have been an employee of Coal and Coke . <br /> OBJECTIOA: See objection to Interrogatory No. 19 . <br /> Interrogatory i;o. 24 . Identify the nature and duration of <br /> the relationship ( if any) between Minerals and Redstone. <br /> RESPONSE: Redstone has been a wholly-owned subsidiary of Minerals <br /> since 1980 . <br /> Interrogatory No. 25 . Identify all alleged business <br /> arrangements between Minerals and Redstone. <br /> a. State the date( s ) of such arrangements . <br /> b. State the nature of such arrangements . Specify the <br /> dates ( if any) when Minerals received payments from Redstone, the <br /> nature of such payments, and the amount paid on each such date . <br /> - 10 - <br />