_GENERAL DOCUMENTS - C1981017 (179)

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Request No. lo . Admit that Minerals was involved in decisions to encumber the assets of Resources in connection with Resources ' loan from Sanwa. OBJECTION: See objection to Request No. 11 . Request No. 17 . Admit that Minerals participated in decisions to obligate Resources to pay its debt and the debts of other corporations and entities to Sanwa. OBJECTION: See objection to Request No. ll . Request No. 18 . Admit that Minerals was involved in the decision to sell Resources ' mine . OBJECTION: The defendant objects to this request on the grounds that it is overly broad and not reasonably calculated to lead to the discovery of admissible evidence. Furthermore, the mine was never sold. Request No. 19 . Admit that Minerals was involved in the negotiations of the sale of Resources ' mine. OBJECTION AAD RESPONSE: The defendant objects to this request on the grounds that it is not reasonably calculated to lead to the discovery of admissible evidence. Request No. 20 . Admit that Minerals made decisions connected with Resources modernization of its mine. OBJECTION A4D RESPO:dSE: The defendant objects to this request on the grounds that it is not reasonably calculated to lead to the discovery of admissible evidence . The modernization of the mine, which began in 1981, has nothing to do with the issues in this lawsuit. III. REQUEST FOR PRODUCTION OF DOCUTAENTS Request No. 1. Please produce each and every financial or employment agreement between Minerals and any officer, director, employee, or independent contractor of Minerals . OBJECTION: Minerals objects to this request on the grounds that it is overly broad and not reasonably calculated to lead to the discovery of admissible evidence . . Requ,;5t No. 2 . Please produce each and every document which reflects any relationship and/or business arrangement between Minerals-and the following companies : a . Resources b. Pitkin Iron - 27 -