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3 . State the basis for the allegation in ¶ 3 of the Amended <br /> Complaint that the performance bond was "personally obtained" by <br /> John A. Reeves and identify each and every employee, <br /> representative, officer, or agent of the Division with knowledge <br /> of the such allegation. <br /> a. For each and every person so identified, state the <br /> nature and extent of such person' s knowledge of or <br /> involvement in such allegation; and <br /> b. Identify each and every communication and each and <br /> every document relating to such allegation. <br /> 4 . Identify each and every employee, representative, <br /> officer, or agent of the Division with knowledge of the May, 1989 <br /> release by the Division of the deed of trust and its replacement <br /> by the performance bond, secured by a deed of trust, filed in 1988 <br /> as alleged in the last sentence of ¶ 3 of the Amended Complaint. <br /> a. For each and every person so identified, state the <br /> nature and extent of such person' s knowledge of or <br /> involvement with the events described in such allegation; and <br /> b. Identify each and every communication and each and <br /> every document relating to such allegation. <br /> 5 . Identify each and every employee, representative, <br /> officer, or agent of the Division with knowledge of Resources' <br /> application to renew the mining and reclamation permit referenced <br /> in ¶ 5 of your Amended Complaint . <br /> a. For each and every person so identified, state the <br /> nature and extent of such person' s knowledge of or <br /> involvement with the renewal application; and <br /> b. Identify each and every communication and each and <br /> every document relating to the renewal application. <br /> 6 . Identify each and every employee, representative, <br /> officer, or agent of the Division with knowledge of the Coal <br /> Reclamation Bond for Use with Deed of Trust referenced in ¶ 9 of <br /> your Amended Complaint . <br /> a. For each and every person so identified, state the <br /> nature and extent of such person' s knowledge of or <br /> involvement with the Coal Reclamation Bond; and <br /> b. Identify each and every communication and each and <br /> every document relating to such bond. <br /> 7 . State the basis for the allegation in ¶ 9 of the Amended <br /> Complaint that the performance bond was "personally obtained" by <br /> - 4 - <br />