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h. Specify the dates ( if any) when Resources extended <br /> credit ( including loans , installment purchase agreements , open <br /> account, etc . ) or guaranteed the extension of credit to Minerals . <br /> If so, state with respect to each instance the date of extension <br /> of credit; the amount of credit extended; the names ) of the <br /> creditor( s ) ; and the name( s ) of the guarantor( s) . <br /> i . Specify the dates ( if any) when Resources made Payments <br /> to any creditor(s) on any extension of credit made to Minerals <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 /> j . Identify all written agreements that relate to and/or <br /> discuss the circumstances specified above. <br /> k. If any oral agreement currently exists or previously <br /> existed that relates to the circumstances specified above, state <br /> the date when it was made, with what officers , agents , or servants <br /> of Minerals and Resources it was made, and what its exact and <br /> complete terms and conditions were. <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 . The <br /> financial arrangements, if any, between Minerals and Resources <br /> have nothing to do with this case. <br /> Interrogatory No. 17 . Identify the nature and duration of <br /> the relationship (if any) between Minerals and Pitkin Iron. <br /> RESP014SE: Pitkin is affiliated with Minerals by virtue of a <br /> majority of the stock of each corporation being held by the same <br /> individuals . <br /> Interrogatory No. 18 . Identify all alleged business <br /> arrangements between Minerals and Pitkin Iron. <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 Pitkin Iron, <br /> the nature of such payments , and the amount paid on each such <br /> date . <br /> C . Specify the dates (if any) when Pitkin Iron 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 Pitkin Iron provided <br /> services and/or facilities for Minerals, the nature of such <br /> - 7 - <br />