Applicant's First Set of Interrogatories and Requests

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Upper Gunnison River Water Conservancy District 02CW038 14. If there is any discovery request which you cannot answer in its entirety or for which you cannot provide the exact information requested: a. Answer any part as to which you have or can obtain the information requested, and provide the information requested to the extent that you know or can obtain such information; b. State your best estimate of all information requested which you do not know and cannot obtain, including without limit, any names or dates for which you lack exact information; C. Describe in detail the basis of your estimate; d. Identify each document, person, or communication upon which your estimate is based; and e. Indicate each part of your response which is an estimate. 15. These discovery requests are continuing innature in accordance withC.R.C.P. 26(e) and require supplementation, correction, and modification as if these discovery requests were asked from time to time prior to trial. INTERROGATORIES AND REQUESTS FOR ADMISSION 1. In fulfilling its statutory duty, pursuant to C.R.S. § 37 -92- 102(3), to appropriate "waters of natural streams and lakes as the board determines may be required for minim stream flows or for natural surface water levels or volumes for natural lakes to preserve the natural environment to a reasonable degree ", how does the CWCB determine the natural environment that should be preserved? In answering this interrogatory, please list each and every factor that goes into such determination and explain how each such factor is considered. 2. Please identify each and every document in your possession or of which you are aware that relates to your answer to the preceding interrogatory. 3. In fulfilling its statutory duty, pursuant to C.R.S. § 37 -92- 102(3), to appropriate "waters of natural streams and lakes as the board determines may be required for 10