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RESPONSE: Minerals has not made a decision regarding the documents <br /> it expects to introduce into evidence, or which any witness may <br /> discuss or refer to at the trial of this matter. <br /> II. REQUEST FOR ADMISSIONS <br /> Request No. 1. Admit that Minerals makes or has made <br /> financial decisions concerning Resources . <br /> OBJECTION: The defendant objects to this request on the grounds <br /> that it is overly broad, vague, and not reasonably calculated to <br /> lead to the discovery of admissible evidence. <br /> Request No. 2 . Admit that Minerals makes or has made <br /> decision which affected the mining operation of Resources . <br /> OBJECTION: See objection to Request No. 1 . <br /> Request No. 3. Admit that Resources was a co-obligor with <br /> Resources for the loan from Continental Illinois National Bank and <br /> Trust Company. <br /> OBJECTION: Minerals objects to this request on the grounds that <br /> it is non-sensical . <br /> Request No. 4 . Admit that Minerals was involved in or <br /> participated in decisions to modernize Resources mine site . <br /> OBJECTION: See objection to Request No. 1 . <br /> Request No. 5 . Admit that Minerals wholly owns Resources . <br /> OBJECTION AND R£SPOYISE: The defendant objects to this request <br /> on the grounds that it is not reasonably calculated to lead to the <br /> discovery of admissible evidence. However, without waiving this <br /> objection, the defendant provides the following response: Admit . <br /> Request No. 6 . Admit that individuals who are directors or <br /> officers of Minerals are also directors or officer of Resources . <br /> RESPOASE: Because of the way the request is phrased, the <br /> defendant cannot admit or deny. However, without waiving its <br /> response, the defendant states that some officers and directors of <br /> Minerals are also officers and directors of Resources , and some <br /> officers and directors of Resources are officers and directors of <br /> Minerals . <br /> Request Wo. 7 . Admit the Minerals held meetings in which <br /> Resources was discussed. <br /> - 25 - <br />