City of Golden's Responses to the State

• Description: RICD
• State: CO
• Basin: South Platte
• Water Division: 1
• Date: 2/13/2001
• Author: Dan Hartman, Glenn E. Prozak, Steven J. Bushong, P. Fritz Hollerman
• Title: City of Golden's Responses to the State
• Water Supply Pro - Doc Type: Court Documents

DISTRICT COURT, WATER DIVISION NiO. 1, STATE OF
Vi
COLORADO
901 9th Avenue, Room 418
Greeley, CO 80631
CONCERNING THE APPLICATION FOR WATER RIGHTS OF
THE CITY OF GOLDEN,
COURT USE ONLY A
IN JEFFERSON COUNTY, COLORADO
Porzak Browning & Bushong LLP
Case Number: 98CW448
Glenn E. Porzak ( #2793)
Steven J. Bushong ( #21782)
Division: 1
P. Fritz Holleman ( #21888)
929 Pearl Street, Suite 300
Boulder, CO 80302
Tel: [phone]
Fax: [phone]
Email: gporzak @pbblaw.com
CITY OF GOLDEN'S RESPONSES TO THE STATE'S FIRST SET OF
INTERROGATORIES,_REQUESTS FOR ADMISSIONS, AND REQUESTS FOR
PRODUCTION OF DOCUMENTS
The City of Golden submits the following responses to the FIRST SET OF
INTERROGATORIES, REQUESTS FOR ADMISSIONS, AND REQUESTS FOR
PRODUCTION OF DOCUMENTS served on Golden by the two State agencies in this matter,
the Colorado Water Conservation Board and the State and Division Engineer (the "State "). The
numbering of these responses may appear to be out of sequence or contain errors of omission
and/or repetition, but is an effort to track exactly the numbers assigned each interrogatory and
request by the State in the discovery request served on Golden.
INTERROGATORIES
Interrogatory No. 2 : Describe any and all method(s) used to assess recreation opportunities and
associated flow needs.
Response: Golden objects to this interrogatory on the grounds that it is confusing,
overbroad, and' burd"ens"ome. ` Without Waivin - those objections; Golden states the
following. It appears that this interrogatory queries what methods Golden used to assess
"recreation opportunities" and associated flow needs prior to the decision by Golden to
allocate funds to build the Golden Whitewater Course (the "Course "). If the question
asks where and how the idea for the course originated, Golden states that the idea was
brought to it by boaters in the area who suggested that Clear Creek in Golden presented a
unique opportunity to create an excellent whitewater course. The boaters made their
case in a variety of public meetings and through many letters to Golden. The letters and
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