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Response: Golden objects to this interrogatory on the grounds that it is overbroad, and <br />burdensome. Without waiving those objections, Golden offers the following list of <br />courses that Gary Lacy, the Course designer, feels are "similar" to the Golden course. <br />1. 2000 - Present: Town of Breckenridge Whitewater Park, Breckenridge Colorado. <br />2. 2000 - Present. 1999 - Present: Gunnison River Whitewater Park, Gunnison, <br />Colorado. <br />3. 1999 - Present: Arkansas River Whitewater Park, Salida, Colorado. <br />4. 1999 - Present: Gore Creek Whitewater Park, Vail, Colorado, 1990 - Present. <br />5. 1999 - 2000: Truckee River Whitewater Park, Reno, Nevada. <br />6. 1999: South Platte River Whitewater Park, Denver, Colorado, <br />7. 1998 Present: Kern River Whitewater Improvements Project, Bakersfield, <br />California. <br />S. 1990: Boulder Creek Whitewater Course, City of Boulder. <br />The remaining information requested, to the extent it is available, can be gleaned from <br />reviewing Mr. Lacy's files on the mentioned projects. Those files will be made available <br />to the State and can be reviewed at a mutually convenient time by prior arrangement with <br />undersigned counsel. <br />Interrogatory No. 4 : Please provide a representative sample of still photographs of the key <br />whitewater features in the course at a variety of flows. We request photographs of course <br />features being used for both slalom racing and playboating/hole riding from flows as low as 50 <br />cfs to those as high as 1,200 cfs, at approximately 100 cfs increments. Photographs should be <br />labeled with the date and the flow when they were taken, and should be keyed to the map <br />supplied in #2 above. <br />Response: Golden object to this interrogatory on the grounds that it is overbroad and <br />burdensome. All photographs in Golden's possession have already been provided in <br />disclosures. If the State would like an explanation of any of the photos already provided, <br />those photos should be identified and Golden will work to provide the desired <br />information. The referenced map was not supplied in the discovery requests. Question <br />92 in the discovery served on Golden contains no reference to a map. <br />Lab0591 4 <br />