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First Set of Interrogatories, Requests for Admissions and Requests for Production of Documents to Applicant
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First Set of Interrogatories, Requests for Admissions and Requests for Production of Documents to Applicant
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Last modified
7/15/2010 1:18:38 PM
Creation date
7/7/2010 4:07:56 PM
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Water Supply Protection
Description
Case No. 00CW281 Breckenridge RICD
State
CO
Basin
Colorado Mainstem
Water Division
5
Date
1/29/2002
Author
Mark T. Pifher, Trout, Witwer & Freeman, P.C.
Title
First Set of Interrogatories, Requests for Admissions and Requests for Production of Documents to Applicant
Water Supply Pro - Doc Type
Court Documents
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6. Please identify, if known, the amount of funds applicant estimates will be expended <br />in the construction of the Whitewater Park. <br />7. Please admit that boaters can use the Whitewater Park during each month at a flow <br />rate of 20 cfs through the reach in which the 15 structures will be located as identified in the <br />application. <br />8. If your response to the preceding request for admission is anything other than an <br />unqualified admission, please state the factual basis for your response, with specific reference to why <br />such activities could not occur at a flow rate of 20 cfs. <br />9. Please describe each structure or device utilized by applicant to control the water in <br />its natural course or location in conjunction with the Whitewater Park. <br />10. Please admit that boating could occur in the Whitewater Park reach in question prior <br />to the installation of the structures referenced in the application. <br />11. If your response to the preceding request for admission is anything other than an <br />unqualified admission, please state the factual basis for your response. <br />12. Please identify the factual basis for the monthly flow amounts sought in the <br />application. <br />13. Please identify the available flow records utilized to determine the now amounts <br />referenced in Interrogatory No. 12. <br />14. Please admit that the appropriation of water in the amounts sought in the application <br />will be approximately equal to the entire flow of the stream in the Whitewater Park reach for the <br />identified months. <br />15. If your response to the preceding request for admission is anything other than an <br />unqualified admission, please state the factual basis for your response, including, based on the <br />historic flow records you have analyzed, an identification of the times when flows exceeded the <br />amounts requested. <br />16. Please admit that the structures identified in the application do not concentrate the <br />flow of water through the reach in question. <br />17. If your response to the preceding request for admission is anything other than an <br />unqualified admission, please state the factual basis for your response, including a description of the <br />extent to which the flows are concentrated. <br />C:\ DATA \Pifher\HOMESTAK \OOCW2 Interrogs.wpd 5 <br />January 29, 2002 (3:15 pm) <br />
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