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waiving these objections, Golden states that its reasons for constructing the course and its <br />studies of the course since construction have all been disclosed to the State already. <br />Interrogatory No. 6: Please provide descriptions of site visits made by recreation experts for <br />the City of Golden. Descriptions should specify dates and flows experienced, purpose of visit, <br />and information about,use of the river (e.g., type of craft used, skill level of boaters, etc.). Field <br />notes from these visits should also be provided. <br />Response: Td the extent the requested information exists, it has already been disclosed <br />in the various Rule 26 disclosures filed in this case, including the expert witness reports <br />prepared by Dr. Raucher, Mr. Lacy, Mr. Thompson and Dr. Danielson. <br />Interrogatory No. 6 : Please provide a list of all competitive events (both slalom and <br />playboating/rodeo /hole riding) held at the course since its construction. The list should identify <br />the name of the event, sanctioning authority, the dates, the range of flows during competition, <br />and the number of competitors. Still photographs and video footage from all competitive events <br />conducted at the course are also requested, with dates and flows identified, and whitewater <br />features keyed to the map supplied in #3 below. <br />Response: Golden objects to this interrogatory on the grounds that it is confusing, <br />overbroad, and burdensome. Much of the information requested has already been <br />provided in disclosures and depositions in this matter, and/or is publicly available. <br />Without waiving _those objections, Golden refers the State. in particular to the expert <br />report of Dr. Raucher and its analysis of events held on the Course. All photographs in <br />Golden's possession have already been provided. If the State would like more specific <br />information on any of the photos provided, Golden will to attempt to identify additional <br />information for specific photos. <br />Interrogatory No. 7 : Please provide a list of any known injuries sustained by boaters while <br />using the course. The list should identify the boater's name and address, the injury, the date, and <br />the flow level. <br />Response; Other than bumps and bruises, Golden is not aware of any injuries on the <br />Course. One -of the reasons that the Course was built is that it is a much safer alternative <br />to kayaking in other parts of Clear Creek, or on other uncontrolled rivers. It gives <br />beginners and others the opportunity to practice and refine their skills in a situation where <br />large eddies and other calm holding areas are part of the design and are easily reachable. <br />Moreover, for boaters in the Course assistance from shore is always close at hand. <br />Interrogatory No. 9 : Please provide a list of all other similar kayak courses designed by the <br />Golden course designers, with basic physical characteristics and descriptions of each course, <br />including: name of the course, length, average gradient, maximum gradient at whitewater <br />features, average channel width, channel width at whitewater features, range of boatable flows, <br />optimum flow range for slalom racing, optimum flow range for playboating. <br />LabOM j <br />