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Upper Gunnison River Water Conservancy District <br />02CW038 <br />3. "Communication" means the transmittal of information (in the form of facts, <br />ideas, inquiries or otherwise) and includes all meetings, discussions, telephone conversations, personal <br />conversations, representations, contacts, letters, memoranda, correspondence, reports, statements, <br />consultations and negotiations. <br />4. The word "person" means any natural person or any business, legal or <br />governmental entity or association. <br />5. "Document" is used in these discovery requests in the broadest sense <br />contemplated by C.R.C.P. 34 and means any item that is subject to a request for production of <br />documents pursuant to C.R.C.P. 34. <br />6. "Explain the basis" means (1) to explain, describe, or state all facts, analyses, <br />opinions, conclusions, inferences, arguments or conjectures supporting the matter, statement, or <br />contention in question; and (2) to identify each person who is knowledgeable about the matter, <br />statement, or contention in question. <br />7. The terms "relate to" or "relating to" mean consist of, refer to, reflect on, arise <br />out of, or in any way or manner legally, factually, or logically connected with the matter discussed. <br />8. When asked to "identify" a document or other tangible thing in these discovery <br />requests, please state the following with respect to each such document: <br />prepared; <br />a. The name and title of the document and the date the document was <br />b. The name, address and telephone number of the author or preparer of <br />the document; <br />C. The location of the document; <br />d. The name, address, telephone number and job title of the person who <br />has custody of or responsibility for the document; <br />e. A description of the contents of the document; and <br />-2- <br />