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Preliminary Interrogatory No. 2. For each person identi- <br /> fied in these interrogatories, please state his or her complete <br /> name, occupation, by whom employed, business address, telephone <br /> number , and the person ' s relationship, if any, to WQCD. <br /> Preliminary Interrogatory No. 3 . a. For each document , <br /> writing, object or thing, requested in this production and not <br /> produced by WQCD with its answers /responses to these <br /> interrogatories and request for production of documents, please <br /> identify it by narrative description, date , and any other <br /> particularities of identification sufficient to singularly <br /> identify such document , writing, object or thing and make it <br /> identifiable for the purposes of further discovery proceedings <br /> under the Colorado Rules of Civil Procedure and/or compliance <br /> with a production request contained in a subpoena duces tecum. <br /> b. Please state the name , title or position, address <br /> and telephone number of the official( s) or employee(s) who has <br /> (have ) possession or a copy of each such document, writing, <br /> object or thing. <br /> C. For each such document , writing, object or thing, <br /> please state its general subject matter and the essentials of <br /> its content , appearance or description. <br /> Preliminary Interrogatory No. 4. a. For each document , <br /> writing, object or thing , requested in this production and <br /> produced by WQCD with its answer / responses to these <br /> interrogatories and requests for production of documents , <br /> please identify it by a narrative description, date, and any <br /> other particularities of identification sufficient to <br /> singularly identify such document , writing, object or thing to <br /> make its identifiable for purposes of a production request <br /> contained in a subpoena duces tecum. <br /> b. Please state the name , title or position, address <br /> and telephone number of the official( s) or employee(s) who has <br /> (have ) possession of each such document , writing, object or <br /> thing. <br /> Specific Interrogatories or <br /> Requests for Document Production <br /> Interrogatory No. 5 . Identify all persons who may or <br /> will appear on behalf of the Division or WQCD as a witness at <br /> any hearing concerning the Notice of Violation which is the <br /> subject matter of this proceeding. Please state whether the <br /> witness will testify as an expert or as a lay witness . <br /> MCR Interrogs to DoH/WQCD - 2 - <br />