_GENERAL DOCUMENTS - C1981017 (180)

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REQUEST FOR ADMISSIONS REQUEST NO. 1 . Admit that you represented Resources in meetings, consultations, and/or negotiations concerning the mine. REQUEST NO. 2 . Admit that you represented Resources before the Mined Land Reclamation Board concerning the mine. REQUEST NO. 3 . Admit that you participated in Resources' permit application issued in 1983 . REQUEST NO. 4 . Admit that you were involved in the determi- nation of Resources' reclamation plan. REQUEST NO. 5 . Admit your involvement in Resources' permit renewal application. REQUEST NO. 6 . Admit that you were involved in the determi- nation of the amount and form of the financial warranty used to ensure reclamation of Resources' mine site. REQUEST NO. 7. Admit that Resources had no money or funds set aside for reclamation other than the financial warranty 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. 26