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g. Identify all written agreements that relate to and/or <br /> discuss the circumstances specified above. <br /> h. 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 ser- <br /> vants of each company or corporation it was made, and what its <br /> exact and complete terms and conditions were. <br /> INTERROGATORY NO. 27. State the full name, residence and <br /> business addresses, and telephone numbers of all of the employees <br /> of Resources who are or who have been employees of Minerals, <br /> Pitkin Iron, Redstone, Redstone Properties, Coal and Coke, <br /> Carbondale Power, and/or Carbondale Mine Services; together with <br /> the date on which they commenced employment and the date on which <br /> (if applicable) they ceased employment; their job title; and a <br /> description of their duties and responsibilities . <br /> INTERROGATORY NO. 28 . State the full name, residence and <br /> business addresses, and telephone numbers of any person or entity <br /> who or which is or has been an independent contractor for one or <br /> more of the following companies or corporations, specifically, <br /> Minerals, Resources, Pitkin Iron, Redstone, Redstone Properties, <br /> Coal and Coke, Carbondale Power, and/or Carbondale Mine Services; <br /> together with the date on which the services commenced and the <br /> date on which (if applicable) the services ceased; and a descrip- <br /> tion of the duties and responsibilities under the agreement or <br /> contract, as well as the purpose of the agreement or contract . <br /> INTERROGATORY NO. 29 . State the full name, residence and <br /> business addresses, telephone number (s) of each person who has <br /> represented Resources in negotiations concerning the Mine, <br /> together with the date (s) of such negotiations, and the nature of <br /> such negotiations . <br /> INTERROGATORY NO. 30 . State the full name, residence and <br /> business addresses, telephone number (s) of each person who has <br /> represented Resources in negotiations concerning environmental <br /> compliance, together with the date (s) of such negotiations, and <br /> the nature of such negotiations. <br /> INTERROGATORY NO. 31 . State the fair market value of the <br /> Rockdust Plant at the time that it was posted as security to <br /> ensure environmental reclamation of the Mine. State the basis <br /> for this determination of fair market value. <br /> a. Identify all persons with responsibility for and/or <br /> knowledge, or who ever have had responsibility or knowledge, of <br /> the fair market value of the Rockdust Plant . <br /> 15 <br />