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Upper Gunnison River Water Conservancy District <br />02CW038 <br />f. The names of any recipients of the document. <br />9. Whenaskedto "produce" any document, please attach a copy to your response <br />or produce such document for inspection and copying at the law office of Alperstein & Covell, P.C., <br />1600 Broadway, Suite 2350, Denver, CO 80202 -4923, or at such other location as may be agreed <br />upon between counsel. <br />10. When asked to "identify" a person, please state the following with respect to <br />each such person: <br />a. Name; <br />b. Address and telephone number where that person can be reached <br />during normal business hours; <br />C. Identity of employer or business of the identified person; <br />d. Job title; and <br />e. Relationship, if any, to the defendants. <br />11. In responding to these discovery requests, please restate in full the <br />interrogatory, request for admission, or request for production of documents to which each response <br />relates. <br />12. If there is any discovery request to which you object in whole or in part, or as <br />to which you claim a privilege in whole or in part, or as to which you claim protection from discovery <br />in whole or in part, state the nature and basis of your objection or claim of protection from discovery; <br />describe in detail the facts upon which you base your objection; and answer any remaining part to <br />which you do not object, do not claim a privilege, or do not claim protection from discovery. <br />13. In responding to these discovery requests, you must furnish all information <br />available to you, including but not limited to information in the possession or control of your <br />attorneys, experts, advisors, agents, associates, or any other person or entity over which you have <br />control. <br />-3- <br />