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....(tee..__ .cw-uri.c. .nn--a-L-.�.-•Y n._em wya.s_-.-. _ ..r.��v-..5..._.-_...____a+.mi . _a._ __. .» ....__-..�_...-__-�. _._�1_� _____.___�.-�__.._.: %w._....^+ it=J�..zsai.-.n_s Lae.aTs._.S.-r9GS�'-A.re.:i, <br /> OBJECTION: Minerals objects to this interrogatory on the grounds <br /> that it is overly broad and not reasonably calculated to lead to <br /> the discovery of admissible evidence . Without waiving this <br /> objection, the defendant responds as follows : <br /> RESPONSE: See responses to No . 3 and No. 10 above. <br /> Interrogatory No. 20. State the full name, residence and <br /> business addresses, and telephone numbers of all of the employees <br /> of Minerals who are or who have been an employee of Pitkin Iron <br /> OBJECTION: See objection to Interrogatory No. 19 . <br /> RESPONSE: See No. 10 above . <br /> Interrogatory No. 21. Identify the nature and duration of <br /> the relationship (if any) between Minerals and Coal and Coke . <br /> RESPONSE: Coal and Coke has been a wholly-owned subsidiary of <br /> Minerals since 1980 . <br /> Interrogatory No. 22 . Identify all alleged business <br /> arrangements between Minerals and Coal and Coke. <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 Coal and Coke, <br /> the nature of such payments, and the amount paid on each such <br /> date. <br /> C . Specify the dates ( if any) when Coal and Coke 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 Minerals provided <br /> services and/or facilities for Coal and Coke, the nature of such <br /> services and/or facilities, and the market value of such services <br /> and/or facilities on each such date. <br /> e . Specify the dates ( if any) when Coal and Coke 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 such 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 Coal and Coke . If <br /> so, 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 /> - 9 - <br />