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INTERROGATORY NO. 60 . Describe and discuss any tasks you <br /> perform or have ever performed as an independent contractor for <br /> each of the companies listed in Interrogatory No. 58 . In your <br /> response separately identify the name of each company and your <br /> respective duties. State the name, title or position of your <br /> immediate supervisor and describe his or her duties and responsi- <br /> bilities . <br /> INTERROGATORY NO. 61 . Other than the documents identified <br /> above, identify any additional documents that you expect to <br /> introduce into evidence or which any person you expect to call as <br /> a witness in this proceeding. <br /> REQUEST FOR PRODUCTION OF DOCUMENTS <br /> REQUEST NO. 1 . Each and every employment or financial <br /> agreement between Mid-Continent Resources, Inc. and any officer, <br /> employee, or independent contractor of that company. <br /> REQUEST NO. 2 . Each and every employment or financial <br /> agreement between Minerals and any officer, employee, or inde- <br /> pendent contractor of that company. <br /> REQUEST NO. 3 . Each and every employment or financial <br /> agreement between Minerals and any officer, employee, or indepen- <br /> dent contractor of Resources. <br /> REQUEST NO. 4 . Each and every employment or financial <br /> agreement between Resources and any officer, employee, or inde- <br /> pendent contractor of Minerals . <br /> REQUEST NO. 5 . Each and every employment or financial <br /> agreement between any officer, employee, or independent contrac- <br /> tor of Minerals and Pitkin Iron, Redstone, Redstone Properties, <br /> Coal and Coke, Carbondale Power, Carbondale Mine Services, or any <br /> other corporation or company which is affiliated financially or <br /> otherwise, or which was a subsidiary of Minerals . <br /> REQUEST NO. 6 . Each and every employment or financial <br /> agreement between any officer, employee, or independent contrac- <br /> tor of Resources and Pitkin Iron, Redstone, Redstone Properties, <br /> Coal and Coke, Carbondale Power, Carbondale Mine Services, or any <br /> other corporation or company which is affiliated financially or <br /> otherwise, or which was a subsidiary of Minerals . <br /> REQUEST NO. 7. Each and every insurance policy or agreement <br /> to hold harmless any officer, employee, or independent contractor <br /> 22 <br />