09/17/2013

IN THE COURT OF COMMON PLEAS OF WASHINGTON COUNTY, PENNSYLVANIA STACEY HANEY, individually and as parent and natural guardian of HARLEY HANEY, a minor, and PAIGE HANEY, a minor, and BETH VOYLES and JOHN VOYLES, husband and wife, ASHLEY VOYLES, individually, LOREN KISKADDEN, individually, GRACE KJSKADDEN, individually, Plaintiffs,
V.

CIVIL DIVISION No. 2012-3534

DEFENDANT'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' FIRST SET OF REQUESTS FOR ADMISSIONS DIRECTED TO DEFENDANT RANGE RESOURCESAPPALACHIA, LLC
Filed on Behalf of Defendant Range Resources - Appalachia, LLC

RANGE RESOURCES - APPALACHIA, LLC, NEW DOMINION CONSTRUCTION, INC., TERRAFIX ENVIRONMENTAL TECHNOLOGY,INC., SKAPS INDUSTRIES, INC., ENGINEERED SYNTHETIC PRODUCTS, INC., RED OAK WATER TRANSFER NE, LLC, MICROBAC LABORATORIES, INC., MULTI-CHEM GROUP, LLC, UNIVERSAL WELL SERVICES, INC., HALLIBURTON ENERGYSERVICES, INC., SAXON DRILLING, L.P., HIGHLAND ENVIRONMENTAL,LLC, EAP INDUSTRIES, INC., and TEST AMERICA, INC., Defendants.

Counsel of Record for This Party: Dennis St. J. Mulvihill, Esquire, PA I.D. #16411 Bruce IL Rende, Esquire, PA I.D. #52714 Erin J. Dolfi, Esquire., PA I.D. #86472

ROBB LEONARD MULVIHILL LLP Firm #249 BNY Mellon Center 500 Grant Street, 23rd Floor Pittsburgh, PA 15219 Telephone: (412) 281-5431 Facsimile: (412) 281-3711

JURY TRIAL DEMANDED.

R0371852.1

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EXHiBIT

09/17/2013

29.

Admit that Range does not know the chemical make-up of all the products used at

the Yeager Site. RESPONSE: Range admits that it does not have an all-encompassing knowledge of the complete chemical formula of every product used at the Yeager Site by Range and/or its subcontractors, as some products contain proprietary compounds which may not be known to Range and many of the MSDS do not list the non-hazardous components of products. To the extent currently possible, the MSDS for the various products used at the Yeager Site have been produced to Plaintiffs. 30. Admit that Range conducted all of its investigations and made findings of water

quality without full knowledge of all chemicals used at the Yeager Site.

RESPONSE: Range admits that it did not have an all-encompassing knowledge of the complete chemical makeup of each chemical product used at the Yeager Site by Range and/or its subcontractors when Range conducted all of its investigations and made findings of water quality as some products contain proprietary compounds, which are not known to Range. However, Range does have a general working knowledge of the chemical makeup of the products used at the Yeager Site. To the extent currently possible, the MSDS for the various products used at the Yeager Site have been produced to Plaintiffs. 31. Admit that at least one outside slope of the Yeager Impoundment failed or

otherwise slide from its original position and had to be reconstructed. RESPONSE: It is denied that at least one outside slope of the Yeager Impoundment failed or otherwise slide from its original position and had to be reconstructed. By way of further responses, while Range admits that there was a slight movement in the surface of sediment trap number 4, it is denied that the outside sloped moved from its original position. 32. Admit that at least one slope of a sediment trap at the Yeager Impoundment failed

or otherwise moved from its original position and had to be reconstructed. RESPONSE: Range admits that there was a slight movement in the surface of sediment trap number 4, but the impoundment's embankment did not move from its original position.

09/17/2013

VERIFICATION
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on behalf of Range Resources - Appalachia.

LLC, verify that I am authorized to execute this Verification and that the statements made in the foregoing Objections and Responses to Plaintiffs' First Set of Requests for Admissions Directed to Defendant Range Resources-Appalachia, LLC are true and correct to the best of my knowledge, information and belief and/or are based upon information that has been provided to me by others, and are made subject to the penalties of 18 Pa.C.SA. 4904 relating to unsworn falsification to authorities.

Date:

By:

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