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employee, representative, officer, or agent of the Division with <br /> knowledge of 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 the circumstances described; and <br /> b. Identify each and every communication and each and <br /> every document relating to such circumstances. <br /> 12 . State the basis for the contention in ¶ 14 of the <br /> Amended Complaint that agents of Resources have failed or refused <br /> to complete the sealing of the adit/rock tunnel and to conduct the <br /> other activities described in such paragraph and identify each and <br /> every employee, representative, officer, or agent of the Division <br /> with knowledge of 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 the circumstances described; and <br /> b. Identify each and every communication and each and <br /> every document relating to such circumstances . <br /> 13 . State the basis for the contention in 1 14 of the <br /> Amended Complaint that the alleged violation poses a danger to the <br /> health or safety of the public and identify each and every <br /> employee, representative, officer, or agent of the Division with <br /> knowledge of 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 the circumstances described; and <br /> b. Identify each and every communication and each and <br /> every document relating to such circumstances . <br /> 14 . Identify each and every employee, representative, <br /> officer, or agent of the Division with knowledge of the Final <br /> Reclamation Schedule referenced in ¶ 15 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 Final Reclamation Schedule; and <br /> b. Identify each and every communication and each and <br /> every document relating to the Final Reclamation Schedule. <br /> 15 . State the basis for the contention in ¶ 15 of the <br /> Amended Complaint that there is "significant environmental harm to <br /> land and water resources and identify each and every employee, <br /> - 6 - <br />