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representative, officer, or agent of the Division with knowledge <br /> 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 /> 16 . State the basis for the contention in 15 of the <br /> Amended Complaint that there are no longer sufficient assets <br /> remaining in Resources' estate with which to perform such <br /> maintenance and reclamation and identify each and every employee, <br /> representative, officer, or agent of the Division with knowledge <br /> 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 /> 17 . State the basis for the allegations of ¶ 17 of the <br /> Amended Complaint and identify each and every employee, <br /> representative, officer, or agent of the Division with knowledge <br /> 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 /> 18 . State the basis for the allegations of ¶ 18 of the <br /> Amended Complaint and identify each and every employee, <br /> representative, officer, or agent of the Division with knowledge <br /> 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 /> 19 . State the basis for the allegations of ¶ 21 of the <br /> Amended Complaint and identify each and every employee, <br /> representative, officer, or agent of the Division with knowledge <br /> of such allegation. <br /> - 7 - <br />