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Duane Dvorak <br />From: Walter Mason tWalter@jesmsea.cornj <br />Sent: Thursday, December 19, 2002 10:28 AM. <br />To: Duane Dvorak <br />Subject: RE: Soil Remediation Case <br />Thanks Duane. I think we can just give them the decision file, as <br />that's what the lawsuit is based on. <br />Walt <br />>>> "Duane Dvorak" <ddvorak@kib.co.kodiak.ak.us> 12/17/02 05:41PM >>> <br />Walt, received your message and planning to have copies made Thursday <br />or Friday. Will keep you informed as we 'move through the holidays. Do <br />we want to include all related information of just the file related to <br />the decision that is being appealed? Specifically, I am referring to <br />all the environmental complaints that have come in since the use began <br />operation. --Duane <br />Message-- <br />Froth: Walter Mason [mailto:Walter@jesmsea.com] <br />Sent: Tuesday, December 17, 2002 10:09 AM <br />To: Duane Dvorak <br />Subject: Soil Remediation Case <br />Duane-- <br />. We have to provide what are called Initial Disclosures to the other <br />side by January 6th, and I'd like to start fleshing those out now. <br />draft the "factual basis of each . . . defense," and we can go over <br />them, but, in the meantime, if you could provide the following that <br />would be great: <br />1. name, address, and phone number of each individual likely to have <br />discoverable information relevant to disputed facts. This would be <br />George, the Brechan people, KIB people involved in the matter, DEC, <br />and <br />the more involved neighbors, as well as any other people that you <br />think <br />might fit within the requirement. <br />2. have any written or recorded statements been made? If so, we need <br />to give the name, address, and phone number of the person along with a <br />copy of the statement. <br />3. a copy of all documents, data compilations, and tangible things <br />relevant to disputed facts. I think we talked earlier about the need <br />to <br />get a copy of everything KIB has that's related to this matter. <br />4. photographs, diagrams and videotapes. Do we have any? <br />Thanks. <br />