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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 />name and address of the addressee and persons to whom copies of the <br />documents were sent; <br />b. the substance or contents of the document; <br />C. the last location of the document; <br />d. the date upon which the document was lost or destroyed; and <br />e. if destroyed, the circumstances of or reason for such destruction and the <br />persons requesting and performing such destruction. <br />6. Objections If you object that a Request is overly broad, burdensome, or oppressive, <br />please state facts or other evidence demonstrating the nature of the burden. <br />III. DISCOVERY REQUESTS. <br />Interrogatories and Requests for Admission. <br />1. For each type of boating vessel intended to use the water flows sought in the <br />application, please identify the minimum amount of water, in terms of a flow rate, which you believe <br />is necessary to allow passage of the kayak, raft, canoe or other such vessel through the identified <br />reach of the Whitewater Park. Explain the factual basis for such identified amount. <br />2. Please identify the maximum amount of water which you believe can flow through <br />the Whitewater Park and be "controlled, concentrated and directed" by the identified structures. <br />Explain the factual basis for such identified amount. <br />3. Please admit that if the application is granted, in whole or in part, applicant intends <br />for the right as decreed to be administered in priority through the identified reach in which the 15 <br />described structures will be located regardless of whether the course is being used by. an individual <br />at any given point in time. <br />4. If your response to the preceding request for admission is anything other than an <br />unqualified admission, please identify the factual basis for your response, including a description of <br />those periods of time during which you did not intend that the right be so administered. <br />5. Please identify the factual basis for applicant's decision to claim water only from <br />April through November rather than year round. <br />C:\ DATA \Piflier\HOMESTAK \OOCW281\First Interrogs.wpd 4 <br />January 29, 2002 (3:15 pm) <br />