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6. "You" and "your" means the Colorado Water Conservation Board, its staff, <br />representatives, agents, insurers, attorneys, employees, directors, officers, subsidiaries, <br />affiliates and all others over whom the Colorado water Conservation Board has control. <br />7. "Boating Course" means the Town of Breckenridge Whitewater Park described in the <br />Application in this matter for which the subject water right's are sought. <br />"Board" means the Colorado Water Conservation Board. <br />9. "CWCB" means the Colorado Water Conservation Board. <br />10. "Diversion structures" means the structures described in paragraph 4 of the Application <br />filed by Breckenridge in this matter. <br />II. INSTRUCTIONS <br />1. Answers and Production Answers to these discovery requests should be delivered to the <br />offices of Porzak Browning & Bushong LLP, Attention: Fritz Holleman, 929 Pearl Street, <br />Suite 300, Boulder, CO 80302, within thirty (30) days of service of this discovery. <br />2. Complete Responses You must respond to each discovery request based on information <br />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 <br />made to ascertain the document's existence. <br />3. Continuing Nature These discovery requests shall be deemed continuing. If additional <br />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 <br />such 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 that a <br />pertinent privilege protects the document or thing from discovery, then please designate <br />the type of document (i.e., letter, report, book, brochure, etc.) and state: <br />a. Information sufficient to enable identification of the document, including the title <br />or subject heading, date name, and address of the author or signer, and the name <br />and address of the 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 in <br />Ph0392 <br />