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6. "You" and "your" means the Town of Breckenridge, staff, representatives, agents, <br />insurers, attorneys, employees, directors, officers, subsidiaries, affiliates and all others over whom <br />the Town of Breckenridge has control. <br />7. "Whitewater Park" means the Town of Breckenridge Whitewater Park described in <br />the Application in this matter for which the subject water rights are sought. <br />8. "Diversion structures" or "structures" means the structures described in the <br />Application filed by Applicant in this matter. <br />II. INSTRUCTIONS <br />1. Answers and Production Answers to these discovery requests should be delivered <br />to the offices of Trout, Witwer & Freeman, P.C., 1120 Lincoln Street, Suite 1600, Denver, CO <br />80203, within thirty (30) days of service of this discovery. <br />2. Complete Responses You must respond to each discovery request based on <br />information which is known, or obtainable through diligent investigation and inquiry. If you do not <br />know, or cannot recall, whether particular responsive documents exist, state the efforts made to <br />ascertain the document's existence. <br />3. Continuing Nature These discovery requests shall be deemed continuing. If <br />additional responsive documents or information that relates to answers to these requests are <br />discovered or come to your attention after .responding, nondisclosure of the documents or <br />information shall be considered a knowing concealment. Demand is hereby made that such <br />additional documents and information be produced immediately upon discovery. <br />4. Privilege If you assert that a document is withheld from production on the grounds <br />that a pertinent privilege protects the document or thing from discovery, then please designate the <br />type of document (i.e., letter, report, book, brochure, etc.) and state: <br />a. Information sufficient to enable identification of the document, including the <br />title or subject heading, date name, and address of the author or signer, and <br />the name and address ofthe addressee and persons copied with the document; <br />b. the location of the document; and <br />C. an explanation of the privilege asserted. <br />5. Destroyed Documents If you are asked to produce a document which was formerly <br />in your possession, custody or control; but the document has been lost or destroyed, then please <br />designate the type of document (i.e., letter, report, book, brochure, etc.) and state: <br />C:\ DATA \Piflrer\HOMESTAK \OOCW28ITirst Interrogs.wpd 3 <br />January 29, 2002 (3:15 pm) <br />