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<br />DISTRICT COURT, WATER DIVISION NO. 5, STATE OF,:,
<br />COLORADO
<br />109 - 8th Street, Suite 104
<br />Glenwood Springs, CO 81601
<br />CONCERNING THE APPLICATION FOR WATER
<br />RIGHTS OF T BRECKENRIDGE
<br />D COURT USE ONLY
<br />Glenn E. Porzak ( #2793)
<br />Case er 00CW281_
<br />Kristin Howse Moseley ( #28678)
<br />Porzak Browning & Bushong LLP
<br />929 Pearl Street, Suite 300
<br />Division: 5
<br />Boulder, CO 80302
<br />Tel: 303 - 443 -6800
<br />Fax: 303 - 443 -6864
<br />Email: gporzak @pbblaw.com
<br />kmoseley @pbblaw.com
<br />FIRST INTERROGATORIES, REQUESTS FOR ADMISSIONS AND REQUESTS
<br />FOR PRODUCTION OF DOCUMENTS TO OPPOSER THE COLORADO WATER
<br />CONSERVATION BOARD`
<br />COMES NOW, the Town of Breckenridge ( "Breckenridge "), the Applicant in Case No.
<br />OOCW281, by and through its undersigned attorneys, and submits the following Interrogatories,
<br />Requests for Admissions and Requests for Production of Documents pursuant to C.R.C.P. 33, 34
<br />and 36. These discovery requests are to be answered by Opposer, the Colorado Water
<br />Conservation Board, in writing and under oath, and should be delivered to the office of the
<br />undersigned counserho later than January 25, 2002.
<br />I. DEFINITIONS
<br />For the purpose of these discovery requests:
<br />The term "document" or "documents" means all documents or tangible things within the
<br />scope of Rule 34, Colorado Rules of Civil Procedure, including, without limitation, deeds,
<br />warranties, permits, correspondence, e -mail, other written messages or communications,
<br />reports, studies, evaluations, memoranda, notes of meetings or conversations, field notes,
<br />diaries, work sheets, drawings, graphs, charts, maps, photographs, sound reproductions,
<br />computer - stored information, and other matter from which information may be obtained
<br />or translated, if necessary, through detection devices, into reasonably usable form. A
<br />request for the production of a document or for the identification of a document shall be
<br />deemed to be a request for the original and all nonidentical copies, including all
<br />reproductions, however made, of the original document which have notations, markings,
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