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e . The effect of the reorganization. <br /> f . An explanation of what happened to Minerals and any <br /> other corporation or entity as a result of the reorganization. <br /> g. A description of any transfer of assets between Minerals <br /> and any other :arson or corporation or entity. <br /> h. A description or any transfer of personnel between <br /> Minerals ' and any other corporation or entity. <br /> OBJECTION: The defendant objects to this interrogatory on the <br /> grounds that it is overly broad, vague and not reasonably <br /> calculated to lead to the discovery of admissible evidence . This <br /> is a case about reclamation of a mine site; the plaintiff has <br /> failed to demonstrate how detailed information regarding Minerals ' <br /> structure has anything to do with the issues in this case. <br /> Interrogatory No. 63 . Explain why Minerals remained dormant <br /> from 1975 through 1980 . <br /> OBJECTIOly: See objection to Interrogatory No . 62 . This <br /> interrogatory is not reasonably calculated to lead to the <br /> discovery of admissible evidence. <br /> Interrogatory No. 64 . Identify the nature and duration of <br /> the relationship ( if any) between Minerals and Sanwa. <br /> OBJECTION: See objection to Interrogatory No . 63 . <br /> Interrogatory No. 65 . Identify all alleged business <br /> arrangements between Minerals and Sanwa. <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 Sanwa, the <br /> nature of such payments, and the amount paid on each such date . <br /> C . Specify the dates ( if any) when Sanwa received payments <br /> from Minerals, the nature of such payments , and the amount paid on <br /> each such date. <br /> d. Specify the dates ( if any) when Minerals provided <br /> services and/or facilities for Sanwa, the nature of such services <br /> and/or facilities, and the market value of such services and/or <br /> facilities on each such date. <br /> e. Specify-, the dates ( if any) when Sanwa provided services <br /> and/or facilities for Minerals , the nature of such services and/or <br /> facilities , and the market value of such services and/or <br /> facilities on each such date . <br /> - 23 - <br />