_GENERAL DOCUMENTS - C1981017 (180)

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submitted to the Division of Minerals and Geology and Mined Land Reclamation Board. REQUEST NO. 8 . Admit that once Resources ceased its mining operation, the fair market value and/or liquidation value of the rockdust plant was insufficient to cover the cost of reclamation. REQUEST NO. 9 . Admit that Resources had no other financial plan to reclaim the mine except for the deed of trust on the rockdust plant. REQUEST NO. 10 . Admit that Resources committed a pattern of violations which then formed the basis for an order to show cause why Resources' permit should not be revoked. REQUEST NO. 11. Admit that Resources never submitted to the Mined Land Reclamation Board an appraisal of the rockdust plant as required by the May 1991 settlement agreement entered as a Board order. REQUEST NO. 12 . Admit that Resources did not make a showing that it could perform reclamation pursuant to the schedule in the May 1991 settlement agreement . REQUEST NO. 13 . Admit that Resources has violated the May 1991 settlement agreement with the Mined Land Reclamation Board by not performing reclamation as required by the agreement. REQUEST NO. 14 . Admit that Resources filed for bankruptcy after Resources agreed to reclaim the Mine according to the schedule set forth in the May 1991 settlement agreement . REQUEST NO. 15 . Admit that Resources has not reclaimed the mine as required by the May 1991 settlement agreement. REQUEST NO. 16 . Admit that Resources submitted no other financial warranty than the rockdust plant to ensure reclamation of the mine. REQUEST NO. 17. Admit that you made decisions concerning environmental compliance at the mine. REQUEST NO. 18 . Admit that you made financial decisions concerning the operation of Resources . REQUEST NO. 19 . Admit that you participated in decisions to amend the reclamation plan. 26