Free Motion for Sanctions - District Court of Colorado - Colorado

Case 1:01-cv-02199-MSK-MEH Document 449-4 Filed 03/07/2007 Page 1 of 2 Case 1 :01-cv-02199 JK-MEH Document 423 Filed Ot. . 1/2006 Page 2 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. OI-MK-2199 (OES)
MICHAEL E. CLA WSON, JARED L. DILLON, THOMAS E. RICHARDS, and JOHN R. BARTLETT,

Plaintiffs,
vs.

MOUNTAIN COAL COMPANY, L.L.c., ARCH WESTERN RESOURCES, L.L.c., and ARCH COAL, INC.
Defendants.

AFFIDA V IT OF PAT MADRAS

I, Pat Madras, being of lawful age and duly sworn under oath, hereby state as
follows:
I. I am the Manager of Corporate HRIS of Arch Coal, Inc.

2. According to company records. as of August 3 I, 2002, Arch Coal, Inc.

had i 4 i employees, Arch Western Resources, L.L.c. had 27 employees, and Mountain

Coal Company, L.L.c. had 320 employees. These figures include full-time and parttime employees and employees on paid leave, but exclude interns.
3.

The EEO-I reports filed by Arch Coal, Inc. on behalf of itself and its
EXHIBIT
103

subsidiaries do not necessarily accurately reflect the number of employees on a

OI-C-02199_
MSK-MEH

MCC 005543

EXHIBIT
:¡ D
:3

~

j
-'

I

I

Case 1:01-cv-02199-MSK-MEH

Document 449-4

Filed 03/07/2007

Page 2 of 2

Case 1:01-cv-02199- .JK-MEH Document 423 Filed Ot.. . ,/2006 Page 3 of 3

company-by-company basis. The company is required to fie EEO-l 's on a location-bylocation basis, and employees of more than one company may work at a single location.
FURTHER AFFIANT SA YETH NOT.

s/Pat Madras Pat Madras

ST ATE OF MISSOURI )
) 5S.

COUNTY OF ST. LOUIS )
Subscribed and sworn to before me this 29th day of April, 2003 by Pat Madras.

s/Erika M. Dominick Notary Public

My commission expires: September 30, 2003

J077197_2.DOC

MCC 005544

-2-