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PETITIONER'S <br /> EXHIBIT <br /> " g <br /> 0 <br /> DISTRICT COURT, TELLER COUNTY, COLORADO <br /> Case No. 92 CV 134, Division 8 <br /> RESPONSES TO PETITIONER'S FIRST SET OF INTERROGATORIES, REQUEST FOR <br /> PRODUCTION OF DOCUMENTS AND REQUEST FOR ADMISSIONS TO RESPONDENTS <br /> OF BAD BOYS OF CRIPPLE CREEK MINING COMPANY, INC., HARRIET SNARE AND <br /> DAVID GRAHAM <br /> THE CITY OF CRIPPLE CREEK, COLORADO, a Colorado municipal corporation, <br /> Petitioner, <br /> V. <br /> BAD BOYS OF CRIPPLE CREEK MINING COMPANY, INC., a Colorado corporation; <br /> HARRIET SNARE; DAVID G. GRAHAM; MOUNTAIN NATIONAL BANK, a Colorado <br /> banking corporation; WOODLAND ESCROW, INC., a Colorado corporation; MAXPRO <br /> CORPORATION, a Colorado corporation; ROGER G. BARRACK; WALLACE F. BURTIS; <br /> JOANNE BURTIS; and GAYNELL HOLCOMB, as the Teller County Treasurer, <br /> Respondents. <br /> Respondents Bad Boys of Cripple Creek Mining Company, Inc., Harriet Snare <br /> and David Graham ("Respondents"), submit these Responses to Petitioners First Set <br /> of Interrogatories, Request for Production of Documents and Request for Admissions <br /> to Respondents Bad Boys of Cripple Creek Mining Company, Inc., Harriet Snare and <br /> David Graham, ("Request"). <br /> GENERAL OBJECTIONS <br /> i <br /> Respondents object to any discovery requested within the Request to the extent <br /> that the Request calls for information or documents outside of the possession or <br /> control of the Respondents, or which are as readily available to Petitioner as to the <br /> Respondents, or which are within the exclusive control of the Petitioner. The <br /> Respondents further object to the discovery requested to the extent that it intends to <br /> require the Respondents to interview or obtain information from persons who are not <br /> associated with the Respondents. <br /> F:lWP5I ETLEADNGSWADBOYSIRESPONSEWF <br />