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Interrogatory No. 6. For all persons identified as lay <br /> witnesses in interrogatory No. 5 , please state their complete <br /> name, occupation, by whom employed, business address , telephone <br /> number , relationship, if any, to WQCD, and the subject matter <br /> about which each lay witness is expected to testify. <br /> Interrogatory No. 7. For all persons identified as <br /> expert witnesses in Interrogatory No. 5, please state their <br /> complete name, occupation, by whom employed, business address, <br /> telephone number , and relationship, if any, to WQCD. Please <br /> state the subject matter to which each expert witness is <br /> expected to testify, the substance of the facts and opinions to <br /> which each expert is expected to testify, and a summary of the <br /> grounds for each opinion. <br /> Interrogatory No. 8. Please identify each document , <br /> writing, object or thing, WQCD intends to mark and offer in <br /> evidence , whether in its case in chief or as potential <br /> rebuttal , in any hearing concerning the Notice of Violation <br /> which is the subject matter of this proceeding. <br /> Interrogatory No. 9. Were any on site inspections or <br /> examinations made of Mid-Continent ' s Outfall No. 016 or this <br /> Outfall' s ponds system made by (a) any WQCD employees or agents <br /> or (b) any other employees or agents of the State of Colorado <br /> during January or February , 1989? If the answer to the <br /> foregoing interrogatory is in the affirmative, please state for <br /> each inspection or on site examination: <br /> ( 1) The calendar date ( s ) and time( s ) of each such <br /> inspection( s) ; <br /> ( 2) By whom such inspection( s) were made (the names of <br /> all persons in any way involved in such inspections) ; <br /> ( 3) Whether any notes were made contemporaneously with <br /> or following such inspection( s) ; <br /> (4) Whether any report( s) were prepared in connection <br /> with such inspection; <br /> ( 5) Whether any sketch(es ) or diagram(s) were made in <br /> connection with any such such inspection(s) ; <br /> ( 6) Whether any photographs or photographic slides or <br /> memoranda were made in connection with any such inspection(s) ; <br /> (7) Whether any water or any other sample(s) was taken; <br /> (8) Whether any water or any other sample(s) taken were <br /> tested. <br /> MCR Interrogs to DoH/WQCD - 3 - <br />