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'JdM TRTUM & RSSOCIRTES TEL = -995-7191 May 11~ J~1L NO.VUL r.U0 <br />DISTRICT COURT, LAS ANI14A6 COUNTY, BTATB OF COLORADO <br />civil Action No. 92 CV 127 <br />DEIEliD71t7T8' lOQRTH BUlpL~'PAI. DIACLOSIIitE CEATIlIC71TE <br />JAMEB.(JIlS) and ANN TATUK, <br />Plaintiffs, ' <br />v. <br />WYOMING FUEL COMPANY and BASIN REBOURCEB,~INC., <br />Defendnnts. <br />Pursuant to Rule 16 of the Colorado Rules of civil procedure, <br />defendant Basin Resouroes, ino. ("Basin"), by end through its <br />attorneys, hereby supplements its previous Disclosure Certificates <br />in this matter as follows: <br />VII. 1[ITNEBBES <br />In addition to the witnesses previously identified, Basin may <br />also call the following witnesses at trial: <br />i. David A. Bailey, o/o Parcel Mauro Hultin i Spannstra, <br />P.C., 1801 California, Suite 3600, Denver, Colorado 80202, <br />telephone 303-292-6400. Until Jana, 1994, Mr. Bailey was oounael <br />of record for Basin Resouroes, Inc. in this matter. Mr. Bailey may <br />be called to testify ragnrdinq a aonvarsation ha had with Jim Tatum <br />during a break in the depoaltlon of Jim Tatum, whioh was taken on <br />september 10, 1993. The substance of that conversation is <br />summarized in Mr. Bailey's a!lidavit of December 1, 1994, a Dopy of <br />which is attached. <br />2. Doe Tekar, Trinidad Railroad, a/o Basin Resources, Inc., <br />14300 Highway 12, Heston, CO 81091. Don Tokar is an employee of <br />Trinidad Railroad who is involved in the maintenance and operation <br />of the railroad tracks that run slong the south border of <br />plaintiffs' property. Mr. Tokar will testify about the care and <br />maintenance of the railroad tracks, apeoifically testifying that <br />the traaka have received only routine maintenance and have shown no <br />signs o! being affected 1n any way by subsidence under or Haar the <br />tracks. <br /><:.-a~. <br />