_GENERAL DOCUMENTS - C1981017 ‎(179)‎

• Permit No: C1981017
• IBM Index Class Name: GENERAL DOCUMENTS
• Doc Name: Bid Documents ‎(IMP)‎ Court Appeals
• Permit Index Doc Type: General Correspondence
• Media Type: D
• Archive: No

has been in existence for approximately 19 years , the amount of
information requested is extremely broad. Furthermore, the
interrogatory is not designed to elicit information that is
relevant to this lawsuit. This action concerns reclamation of the
Mine, and this interrogatory requests all information that has
anything at all to do with the Mine. As such, it is overly broad,
and not calculated to lead to the discovery of admissible
evidence.
Interrogatory No. 37 . State the full name, residence and
business addresses , telephone number(s) of each person who has
represented Minerals in negotiations concerning the Mine, together
with the date( s ) of such negotiations , and the nature of such
negotiations .
OBJECTION: See objection to Interrogatory No. 36 .
Interrogatory No. 38. State the full name, residence and
business addresses, telephone number( s ) of each person who has
represented Minerals in negotiations concerning environmental
compliance, together with the date( s ) of such negotiations , and
the nature of such negotiations .
OBJECTION: See objection to Interrogatory No . 36 .
Interrogatory No. 39 . Identify each person who attended, or
participated in meetings, consultations , and the negotiations
referred to in Interrogatories 36 , 37 , and 38 who is a director,
officer, or employee of Resources .
OBJECTION: See objection to Interrogatory No. 36 .
Interrogatory No. 40. For each duly called meeting of the
board of directors of Minerals , state the date of the meeting, the
names of the persons in attendance, whether minutes were kept of
such meeting, and the location of such minutes (if any) .
OBJECTION1: The defendant objects to this interrogatory on the
grounds that it is not reasonably calculated to lead to the
discovery of admissible evidence. Without waiving this objection,
the Defendant states that the Board of Directors of Minerals have
met at approximately quarterly intervals since 1980, when Minerals
was activated. The Directors were present and from time-to-time,
Auditors , loan officers , directors of other corporations , and
other persons attended, all as set forth in the Minutes of the
meetings which are in the custody of Robert Delaney at 818
Colorado Avenue, Glenwood Springs , Colorado .
Interrogatory No. 41. For each duly called meeting of the
shareholders of Minerals, state the date of the meeting, the names
of the persons in attendance, whether minutes were kept of such
meeting, and the location of such minutes ( if any) .
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