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ENFORCE23476
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Last modified
8/24/2016 7:32:44 PM
Creation date
11/21/2007 10:26:53 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981013
IBM Index Class Name
Enforcement
Doc Date
9/10/1993
Doc Name
DEPOSITION
Violation No.
CV2000009
Media Type
D
Archive
No
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(Deposition of James Tatum) <br />1 Deposition Exhibits 25 and 26.) <br />~ 2 <br />Q. Mr. Tatum, I will hand you what has <br />3 been marked as Exhibits 25 and 26, and ask you if <br />4 you recognize those documents? <br />5 A. I do. <br />6 Q. For the record, Exhibit 25 is a May the <br />7 11th, 1989, letter from Bill Garner to Jim Tatum, <br />8 and Exhibit 26 is a May 17, 1989, letter from Mr. <br />9 Tatum to Bill Garner, G-a-r-n-e-r. Now, is it your <br />10 understanding that Exhibit 25 was implementing the <br />11 June 1st letter agreement? <br />12 A. No, I don't think so. I think we had <br />~ 13 some earlier correspondence from Garner saying that <br />14 he really didn't understand what had been done <br />15 between -- have you not seen Garner's letter to me <br />16 of April 6 of '89? <br />17 Q. I have seen it. I guess I was focusing <br />18 on prepared agreements or draft deeds intended to <br />19 implement the June 1st letter rather than just <br />20 correspondence between the two of you. This, in <br />21 my files, was somebody or anybody's first attempt <br />22 to implement the June 1st agreement by some form of <br />23 subsequent agreement, and I wanted to see if that <br />24 was consistent with your recollection or with your <br />25 records? <br />22 <br />MEEK & ASSOCIATES <br />3016 3rd Ave., Pueblo, Co 81008 (719) 542-1010 <br />
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