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111 !l. C_J VL 1 VL V - [ .JV A 11 I -II ALA* NA1.V •SAL 1. I)u M-Ik-A- A f. - AA IIV. 1 • VW VI) <br />Jollu Cyran, Esq. <br />Susan Schneider, ES4_ <br />/11:61 23, 2002 <br />1"'agc 2 <br />cicilc>sitiol tcs[irtlony in lieu of live teslipioiay for Mr. Knox. Altllougll that its not our prLferenec, <br />it would ail least address Ken's schedule and titc trial schedule constraints, Ilowevcr, that would <br />r1ccd lc) Zipply eclu"Illy t4 both 1 In other words, if we forego the right to cilll K ell ill p ersoll, <br />so does the SMtc. <br />3. .loi indicated illere were minor cl1W - 19Cs to some State exhibits and that he would <br />t;cr►c1 those to t ts "Is well as exhibits that were previously not in cluded with t he Slate's trial <br />e xhibits. Th ose are referenced agra'n't In t he letter 1 ruccived iron - i John today. Until I rcccivc the <br />�locuillcnts, I Cannot identify zt11y SliC�cific pre- trial ol)jcctiolis. Af;aiit, we do notb ClleVC it is <br />adcquatc to simply reference it deposition exhibit, without providing a copy. <br />4. As %nclieaLcd the Vail and Breckenridge exhibits lists, soillc exhibits play be <br />elll.irgcd or co lorized. The Applicants intend to uS fu11 -size maps, but reduced versions of those <br />wi;rc alrGacly l�s'avidc:cl to the State. lip. addition, Applicants have talcen the design plaits for 1 30 1 - 11 <br />whitcwntcr parks and colorized 1,110111 for ilhistration purposes 9 . 1 - trial. In addition, Breckenridge <br />enlarged the colorized version to make it more readily visible. The enlarged, colorized vcrsic�ns <br />arc, tIvaihiblc at our offices for review. Plcase note, lnowevcr, that those illi,sttative exhibits :zre in <br />every other respect the same as the exhibits you were provided. <br />'5. As I informed John, the District exhibit list mistalcenly lists S omc.exhibits with <br />the prc -fix "D ". All exhibits Dave the pre -Cx "V." ral1ri.inciieated that was fille. <br />G. We still bavc a conecnl regarding the photobraphS th Were 'lot prcvi0ttsly <br />dtscloscd by t11e SL rltc. Based Upon all C corres p oldonce from John he represented that all <br />those exhibits were providc;d at Ted ICowalslci's deposition. Both Glenn :and I'1-1t7 disagree. <br />Copies were rrlade cat' t1l the clisclosedphotographs aitd 111a photogral)lts icierltified in the <br />Breckenridoc and District exhibit objections were not inchidcd with the E9isclosur�s, I'leasc <br />cl-jecic again with':1`ed Kowalski. Thanks. <br />Sincerely, <br />PORZAK BROWNINCr & BUSI LLP <br />S tcvcn ,� i s io <br />I'd 7OSi <br />