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Request for Production of Documents No. 10 Still photos and/or video footage of a <br />representative sample of other kayak courses designed by the Golden course designer, with flow <br />levels identified for when the photos were taken. <br />Response: To the extent these materials exist, they are in Mr. Lacy's files and may be <br />viewed at a mutually convenient time by prior arrangement with undersigned counsel. <br />Request for Production of Documents No. 11 : Still photos and/or video footage of the site <br />taken before, during, and after construction. <br />Response: To the extent the requested materials exist, Golden believes they have already <br />been provided to the State in Golden's various disclosures in this matter. Golden is also <br />aware of a June 7, 1998 video tape made by a local news station. Golden has recently <br />acquired that tape and is making a copy of that tape for the State. There is also <br />apparently a video shot by a Denver television station for a program called "Colorado <br />Getaways." Golden has been trying to find a copy of that video, but does not have one <br />yet. If it is found, it will be provided to the State. <br />Request for Production of Documents No. 12 : All contract documents with Mr. Lacy and <br />Aquatic and Wetland Co., and any other contractors involved. <br />Response: To the extent the requested materials exist, Golden believes they have already <br />been provided to the State in Golden's various disclosures in this matter. <br />Request for Production of Documents No. 13 : Any promotional or demonstrative literature, <br />still photos and/or video footage concerning the course. <br />Response: To the extent the requested materials exist, Golden believes they have already <br />been provided to the State in Golden's various disclosures in this matter. There are also <br />the two videos mentioned in response to No. 11 above. <br />Request for Production of Documents No. 14 : Any surveillance videos of the course or the <br />parking lot near the course. <br />Response: Golden does not have any such videos. <br />LabO591 6 <br />