1989-11-03_GENERAL DOCUMENTS - C1981017

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OCT 1 4 f9gg LC BEFORE THE DEPARTMENT OF HEALTH NOV • � 1989 STATE OF COLORADO MINEr) FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS PROPOUND BY MID-CONTINENT RESOURCES, INC. TO WATER QUALITY CONTROL DIVISION, COLORADO DEPARTMENT OF HEALTH IN THE MATTER OF THE NOTICE OF VIOLATION ISSUED FEBRUARY 22, 1989, TO MID-CONTINENT RESOURCES, INC. PITKIN COUNTY, COLORADO. Mid-Continent Resources, Inc. (hereinafter "Mid-Contin- ent " ) hereby propounds interrogatories to the Water Quality Control Division ( "WQCD" ) pursuant to Rule 33, Colo. R. Civ. P. , 7A Colo. Rev. Stat . ( 1977 Repl . Vol . ) , and Rule 2 . 1 .4.G. of the Rules for all Proceedings before the Water Quality Control Commission and WQCD. Mid -Continent requests the production of certain documents by WQCD pursuant to Rule 34, Colo. R. Civ. P. , 7A Colo . Rev . Stat . ( 1977 Repl. Vol . ) , and Rule 2 . 1 .4.G of the Rules for all Proceedings before the Water Quality Control Commission and WQCD, by attaching copies of the same where this can be reasonably accomplished . For documents which cannot be reasonably attached to this request for production , please state the location, date( s ) and time( s ) (providing several alternatives ) , what condition ( s ) , if any, under which such documents can be examined and/or copied and whether it will be necessary for Mid-Continent to arrange for its own copying machine to make any copies it desires . Preliminary Interrogatories Preliminary Interrogatory No. 1 . Identify all persons answering these interrogatories and related requests for production of documents . If more than one person provides an answer , indicate for each answer or portion thereof the person or persons answering and the part of the answer for which each person is responsible. MCR Interrogs to DoH/WQCD - 1 -