Identification of Persons, Documents and Tangible Things Not Otherwise Disclosed

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I mac' DISTRICT COURT, WATER DIVISION NO. 4, STATE OF COLORADO Montrose County Justice Center 1200 North Grand Avenue Bin A Montrose, CO 81401 -3146 970.249.2859 CONCERNING THE APPLICATION FOR WATER RIGHTS OF THE UPPER GUNNISON RIVER WATER CONSERVANCY DISTRICT A COURT USE ONLY A IN GUNNISON COUNTY Cynthia F. Covell, #10169 Case Number: 02CW038 Alperstein & Covell, P.C. Gilbert Y. Marchand, Jr., Of Counsel, #19870 1600 Broadway, #2350 Water Division No. 4 Denver, CO 80202 -4923 Phone: (303) 894 -8191 Fax: (303) 861 -0420 IDENTIFICATION OF PERSONS, DOCUMENTS AND TANGIBLE THINGS NOT OTHERWISE DISCLOSED PURSUANT TO C.R.C.P. 26(a)(1) Applicant, Upper Gunnison River Water Conservancy District ( "District"), through its undersigned attorneys, pursuant to section III of the Case Management Order, submits the following identification of all persons who might be called as witnesses, as well as documents and tangible things which might be introduced at trial, not otherwise disclosed pursuant to C.R.C.P. 26(a)(1): The District interprets this identification requirement as pertaining to matters that are the subject of C.R.C.P. 26(a)(1) disclosure. Thus, this identification does not include persons, documents, and tangible things that are the subject of C.R.C.P. 26(a)(2) disclosure requirements. Nor is it intended to include as yet unprepared trial exhibits whose identification and exchange are governed by other provisions of the Case Management Order and the as yet unprepared Trial Management Order. I. PERSONS WHO MIGHT BE CALLED AS WITNESSES NOT OTHERWISE DISCLOSED PURSUANT TO C.R.C.P. 26(a)(1) OR C.R.C.P. 26(a)(2): None at this time. The District reserves the right to supplement this as may be allowed by section III of the Case Management Order, the Colorado Rules of Civil Procedure, and/or order of this court.