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OBJECTION: The defendant objects to this interrogatory on the <br /> grounds that it is overly broad and vague. Without waiving this <br /> objection, Minerals provides the following response. <br /> RESPONSE: Minerals does not conduct operations in Gunnison or <br /> Pitkin Counties, Colorado, but does maintain an office at 1058 100 <br /> Road, Carbondale, Colorado in Garfield County. It is managed by <br /> the officers and directors listed under No. 3 above . <br /> Interrogatory No. 15 . Identify the nature and duration of <br /> the relationship ( if any) between Minerals and Resources . <br /> RESPONSE: Resources has been a wholly-owned subsidiary of <br /> Minerals since 1980 . <br /> Interrogatory Wo. 16 . Identify all alleged business <br /> arrangements between Minerals and Resources . <br /> a. State the date( s) of such arrangements . <br /> b. State the nature of such arrangements . Specify the dates <br /> ( if any) when Minerals received payments from Resources, the <br /> nature of such payments , and the amount paid on each such date. <br /> C . Specify the dates ( if any) when Resources received <br /> payments from Minerals , the nature of such payments, and the <br /> amount paid on each such date . <br /> d. Specify the dates ( if any) when Resources provided <br /> services and/or facilities for Minerals , the nature of such <br /> services and/or facilities , and the market value of such services <br /> and/or facilities on each date . <br /> e. Specify the dates (if any) when Minerals provided <br /> services and/or facilities for Resources , the nature of such <br /> services and/or facilities , and the market value of such services <br /> and/or facilities on each date . <br /> f . Specify the dates ( if any) when Minerals extended credit <br /> ( including loans, installment purchase agreements, open account, <br /> etc . ) or guaranteed the extension of credit to Resources . If so, <br /> state with respect to each instance the date of extension of <br /> credit; the amount of credit extended; the name( s) of the <br /> creditor( s ) ; and the name( s ) of the guarantor(s ) . <br /> g. Specify the dates ( if any) when Minerals made payments <br /> to any creditor(s) on any extension of credit made to Resources <br /> ( including loans, installment purchase agreements , open account, <br /> etc . ) . If so, state with respect to each instance- the date of the <br /> payment; the amount of the payment; the name(s ) of the <br /> creditor(s ) ; and the name ( s ) of the guarantor( s) . <br /> - 6 - <br />