Applicant's First Set of Interrogatories and Requests (2)

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Upper Gunnison River Water Conservancy District 02CW038 2. If YOU do not have enough personal knowledge to fully answer an interrogatory, say so, but make a reasonable and good faith effort to the get the information by asking other persons or organizations, unless the information is equally available to the asking party. 3. Whenever an interrogatory may be answered by referring to a DOCUMENT, the DOCUMENT may be attached as an exhibit to the response and referred to in the response. If the DOCUMENT has more than one page, refer to the page and section where the answer to the interrogatory can be found. 4. YOUR answers to these interrogatories must be verified, dated, and signed. 5. Please repeat the Interrogatory before stating the answer. (This instruction is not taken from C.R.C.P. Form 20.) DEFINITIONS 6. The terms "ENGINEERS" or "YOU," "YOUR," or "ANYONE ACTING ON YOUR BEHALF" includes the Colorado State Engineer and/or Division Engineer, Water Division No. 4, and their agents, employees, attorneys, accountants, investigators , and anyone else acting on their behalf. (This definition is modified from C.R.C.P. Form 20.) 7. PERSON includes a natural person, firm, association, organization, partnership, business, trust, corporation, or public entity. (C.R.C.P. Form 20.) 8. DOCUMENT means a writing, as defined in CRE 1001 and includes the original or a copy of handwriting, typewriting, printing, photostating, photographing, and every other means of recording upon any tangible thing and form of communicating or representation, including letters, words, pictures, sounds, or symbols, or combinations of them. (C.R.C.P. Form 20.) 9. ADDRESS means the street address, including the city, state and zip code. (C.R.C.P. Form 20.) The following word used in these requests for discovery is not found in C.R.C.P. Form 20, and are defined as follows: -2-