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Applicant's Response Consenting to CWCB's Motion to Supplement Expert Disclosures
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Applicant's Response Consenting to CWCB's Motion to Supplement Expert Disclosures
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Last modified
1/26/2010 4:41:47 PM
Creation date
7/30/2009 1:21:06 PM
Metadata
Fields
Template:
Water Supply Protection
File Number
8230.2B2
Description
Discovery
State
CO
Basin
Colorado Mainstem
Water Division
4
Date
8/13/2003
Author
Cynthia F. Covell
Title
Applicant's Response Consenting to CWCB's Motion to Supplement Expert Disclosures
Water Supply Pro - Doc Type
Court Documents
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DISTRICT COURT, WATER DIVISION NO. 4, . <br />. <br /> <br />STATE OF COLORADO ; <br />r, <br />"?? ° <br />Montrose County Justice Center et}???L <br />1200 North Grand Avenue Bin A <br />Montrose, CO 81401-3146 <br />970.249.2859 <br />CONCERNING THE APPLICATION FOR WATER <br />RIGHTS OF THE UPPER GUNNiSON RIVER <br />WATER CONSERVANCY DISTRICT AL COURT USE ONLY A <br />IN GUNNISON COUNTY <br />Cynthia F. Covell, #10169 Case Number. 02CW038 <br />Alperstein & Covell, P.C. <br />Gilbert I. Marchand, Jr., Of Counsel, #19870 <br />1600 Broadway, #2350 Water Division No. 4 <br />Denver, CO 80202-4923 <br />Phone: (303) 894-8191 <br />Fax: (303) 861-0420 <br />cfc(a)Apersteincovell.com <br />APPLICANT'S RE5PONSE CONSENTING TO CWCB'S MOTION TO <br />5UPPLEMENT EXPERT DISCLOSURES <br />Applicant, Upper Gunnison River Water Conservancy Disirict ("applicant" or "District"), <br />through its undersigned attorneys, responds as follows to the motion to supplement expert disclosures <br />filed by objector Colorado Water Conservation Boazd ("CWCB"): <br />1. The deadline for the CWCB's expert disclosures was originally June 18, 2003. The <br />CWCB obtained a one week extension of that deadline and served its expert disclosures on June 24, <br />2003. At the July 21, 2003 deposition of CWCB's designated expert, Randy Seaholm, results of a <br />computer model "run" were first provided to applicant. On July 29, 2003, the CWCB filed its motion <br />to supplement expert disclosures. Attached to the motion was the CWCB's "Supplement to the <br />Expert Report" of Randy Seaholm. As reflected in the CWCB's motion, the supplemental expert <br />disclosures sought to be made by the CWCB involve the running and interpreting of a computer <br />model concerning water availability an the Upper Gunnison River. <br />2. In its motion, the CWCB acknowledged that applicant "may further question [Mr. <br />Seaholm] regarding the modeling study and supplemental report" at the continuation of Mr. <br />Seaholm's deposition. Provided applicant is indeed able to depose Mr. Seaholm on the modeling <br />O ?... <br />f r? <br />` <br />1-P! C-J-- '4,Y??r
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