First Interrogatories, Request for Admissions and Requests for Production of Documents to Opposer

• Description: Case No. 00CW281 Breckenridge RICD
• State: CO
• Basin: Colorado Mainstem
• Water Division: 5
• Date: 12/27/2001
• Author: Glenn E. Porzak, P. Fritz Hollerman, Krisitn Howse Moseley
• Title: First Interrogatories, Request for Admissions and Requests for Production of Documents to Opposer
• Water Supply Pro - Doc Type: Court Documents

your possession, custody or control; but the document has been lost or destroyed, then
please designate the type of document (i.e., letter, report, book, brochure, etc.) and state:
a. information sufficient to enable identification of the document, including the title
or subject heading, date, name and address of the author or signer, and name and
address of the addressee and persons to whom copies of the documents were sent;
b. the substance or contents of the document;
C. the last location of the document;
d. the date upon which the document was lost or destroyed; and
e. if destroyed, the circumstances of or reason for such destruction and the persons
requesting and performing such destruction.
6. Objections If you object that a Request is overly broad, burdensome, or oppressive,
please state facts or other evidence demonstrating the nature of the burden.
III. DISCOVERY REOUESTS
A. Interrogatories and Requests for Admission:
Identify any and all official actions that the Board has taken in connection with the
Statement of Opposition filed by the CWCB in this matter, including, but not
limited to, authorization of the Statement of Opposition that it filed.
2. Please admit that the CWCB does not own or have any legally cognizable interest
in any water right that could be injured by the Application for water rights filed by
Breckenridge in this matter.
3. If your response to the preceding request for admission was anything other than an
unqualified admission, please answer the following questions with respect to any
water right that you contend could be injured by the water right sought by
Breckenridge in this matter:
a. Name of water right;
b. Nature of your interest in the water right and identity of the
documents creating or evidencing said interest;
C. Name of the structure through which the water right is diverted or
in which it is stored;
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