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the sufficiency of the deed of trust to the rockdust plant to <br /> cover reclamation costs, any change in the liquidation value of <br /> the rockdust plant, any change in the determination that the deed <br /> to the rockdust plant was an insufficient financial warranty to <br /> cover the costs of reclamation, and the plan of action to respond <br /> to such insufficiency. <br /> INTERROGATORY NO. 11. Identify each and every time you repre- <br /> sented Resources in meetings or discussions with the Division of <br /> Minerals and Geology concerning the mining operation of Mid-Cont- <br /> inent Resources since the time the company applied for its permit <br /> from that agency. Specifically include the dates and a summary <br /> of the matter (s) involved for each occurrence. <br /> INTERROGATORY NO. 12 . Identify each and every time you repre- <br /> sented Resources in front of the Mined Land Reclamation Board <br /> since the time Resources applied for its permit . Specifically <br /> include the dates and a summary of the matters involved for each <br /> occurrence. <br /> INTERROGATORY NO. 13 . Identify each and every time you attend- <br /> ed a meeting or hearing of the Mined Land Reclamation Board in <br /> conjunction with a matter concerning the mining operation of Mid- <br /> Continent Resources. Specifically include the dates and a <br /> summary of the matter (s) involved for each occurrence. <br /> INTERROGATORY NO. 14 . State your involvement and knowledge of <br /> the corporate reorganization in which Mid-Continent Resources, <br /> Inc. became a wholly-owned subsidiary of Mid-Continent Minerals. <br /> Include the following information: <br /> a. The purpose of the reorganization; <br /> b. The effect of the reorganization; <br /> C. An explanation of what happened to both corporations <br /> because of the reorganization; <br /> d. A description of the assets and liabilities moved <br /> between the two corporations; <br /> e. State and explain any connection between the reorgani- <br /> zation and the decision to modernize Mid-Continent Resource' s <br /> mining operation beginning in 1981 . <br /> f. Identify each person with whom you discussed the above <br /> matters and/or who participated in the decisions concerning the <br /> reorganization. <br /> 9 <br />