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DISTRICT COURT, WATER DIVISION NO. 5,
<br />Court Address: 109 8 t '' Street, Suite 104
<br />Glenwood Springs, CO 81601
<br />CONCERNING THE APPLICATION FOR WATER
<br />RIGHTS OF THE TOWN OF BRECKENRIDGE
<br />A COURT USE ONLY A
<br />Mark T. Pifher, #12629
<br />Case Number: OOCW281
<br />Trout, Witwer & Freeman, P.C.
<br />1120 Lincoln Street, Suite 1600
<br />Denver, Colorado 80203
<br />Tele: (303) 861 -1963
<br />Div.: 5 Ctrm.:
<br />Fax: (303) 863 -4465
<br />E -Mail: mpifher@,troutlaw.com
<br />FIRST SET OF INTERROGATORIES, REQUESTS FOR ADMISSIONS AND
<br />REQUESTS FOR PRODUCTION OF DOCUMENTS TO APPLICANT,
<br />THE TOWN OF BRECKENRIDGE
<br />The Homestake Project, by and through their undersigned counsel, hereby submit the
<br />following first set of interrogatories, requests for admissions and requests for production of
<br />documents to Applicant pursuant to C.R.C.P. 33, 34 and 36. These discovery requests are to be
<br />answered by Applicant, the Town of Breckenridge, in writing and under oath, and should be
<br />delivered to the office of the undersigned counsel no later than March 4, 2002.
<br />I. DEFINITIONS
<br />For the purpose of these discovery requests:
<br />1. The term "document" or "documents" means all documents or tangible things within
<br />the scope of Rule 34, Colorado Rules of Civil Procedure, including, without limitation, deeds,
<br />warranties, permits, correspondence, e-mail, other written messages or communications, reports,
<br />studies, evaluations, memoranda, notes of meetings or conversations, field notes, diaries, work
<br />sheets, drawings, graphs, charts, maps, photographs, sound reproductions, computer- stored
<br />information, and other matter from which information may be obtained or translated, if necessary,
<br />through detection devices, into reasonably usable form. A request for the production of a document
<br />or for the identification of a document shall be deemed to be a request for the original and all
<br />nonidentical copies, including all reproductions, however made, ofthe original document which have
<br />notations, markings, comments or other material not appearing in the original. The term "document"
<br />
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