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4 . If you are unable to produce a document requested but <br /> are aware of its location, please identify the person in <br /> possession, custody or control of the document and state where the <br /> document can be found. <br /> 5 . If 'you withhold a requested document under claim of <br /> privilege, please describe that document by date and general <br /> content, identify all persons who participated in the preparation <br /> or transmission of that document as well as all persons who have <br /> received a copy of or read, examined or reviewed that document, <br /> and state the basis on which the asserting privilege is claimed. <br /> 6 . This request for production of documents is a continuing <br /> one. If at any time you obtain or become aware of any further <br /> documents responsive to this request, please identify and produce <br /> such additional documents . <br /> Documents Requested <br /> 7_. Each and every document identified in response to the <br /> foregoing Interrogatories, including, but not limited to: <br /> a. The Mining and Reclamation Permit No. C-81-017; <br /> b. The 1984 performance bond and deed of trust; <br /> C. The permit renewal application filed on or about <br /> December 1, 1987; <br /> d. The Coal Reclamation Bond for Use with Deed of <br /> Trust; <br /> e. Each and every Notice of Violation; <br /> f. The July 17, 1990 order to show cause; <br /> g. The Settlement agreement dated on or about May 22, <br /> 1991; and <br /> h. The Final Reclamation Schedule. <br /> 8 . Each and every document which refers or relates to any <br /> of the documents listed above. <br /> 9 . Each and every communication and document, in addition <br /> to those which are produced in response to the foregoing <br /> interrogatories, which refers or relates in any way to any of the <br /> defendants, Resources, the subject mine site, or any other aspect <br /> of the subject matter of this action, including, without <br /> limitation, communications and documents between the Division and <br /> the Mined Land Reclamation Board and those between the Division <br /> and the United States Office of Surface Mining. <br /> - 11 - <br />