_GENERAL DOCUMENTS - C1981017 (180)

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D. Privilege. If any privilege is claimed as to any information called for or any document or oral communication requested to be identified by an interrogatory: (1) Identify the privilege involved (eq. , attorney-client, work product, etc. ) ; (2) State the basis for the claim of privilege as to each specific item of information, document, or oral communication; (3) If the privilege is claimed with respect to any infor- mation, identify each person who has knowledge of such informa- tion, or to whom such information has been communicated at any time, in any way; and (4) If the privilege is claimed as to any document or oral communication, (a) state the type of document or communication and the date thereof; (b) identify each person who prepared or made it and each person, if any, who signed it; (c) identify each person to whom the document or communication or any copy, summary, digest, or other description thereof was directed, circulated, or distributed; and (d) identify each person now in possession of the document or such copy, summary, digest, or other description. E. Minerals . The term "Minerals" as used herein means defendant Mid-Continent Minerals Corporation a/k/a Mid-Continent Minerals, Inc. , and its subordinates, employees, agents, repre- sentatives, or any other persons, agencies, or organization acting in behalf of Minerals. F. The Mine. The term the "Mine" as used herein means the Coal Basin Mines, located in Pitkin, Garfield, and Gunnison Counties, Colorado. G. Resources . The term "Resources" as used herein means Mid-Continent Resources, Inc. , formerly known as Mid-Continent Coal & Coke Company, and its subordinates, employees, agents, representatives, or any other persons, agencies, or organization acting in behalf of Resources . H. Pitkin Iron. The term "Pitkin Iron" as used herein means Pitkin Iron Corporation, and its subordinates, employees, 3