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DMG Experts <br /> 3. DMG anticipates the potential need for the following experts: <br /> a. An attorney to testify regarding the propriety of DMG's <br /> counterclaim which MCR alleges is frivolous and <br /> groundless. <br /> b. An expert to testify concerning the standard of care and <br /> duties imposed upon Louis LaGiglia as the Creditors' <br /> Trustee under MCR's liquidation plan. <br /> C. DMG at present does not anticipate retaining or specially <br /> employing any other witnesses to provide expert testimony. <br /> However, some of the information held by the persons <br /> listed in response to Rule 26(a)(1) may include opinions <br /> based upon each individual's individual knowledge, skill, <br /> experience, training, and education. <br /> d. DMG will provide the disclosure required by Rule <br /> 26(a)(2)(C) on or before April 1, 1998. The Plaintiffs and <br /> MCR will have until May 1, 1998 to identify any rebuttal <br /> experts and provide their expert reports. <br /> C. The parties acknowledge that they have a continuing duty to timely <br /> supplement or correct their disclosure statements pursuant to Rule 26(a)(1) and (e), COLO. <br /> R. Civ. P. <br /> III <br /> IDENTIFICATION OF PERSONS, DOCUMENTS, AND TANGIBLE THINGS <br /> A. Plaintiffs' Identification <br /> Plaintiffs shall identify all additional persons who might be called as <br /> witnesses as well as additional documents and tangible things to be introduced at trial, not <br /> otherwise disclosed pursuant to Rule 26(a)(1), not later than June 1, 1998. <br /> In addition to all documents and tangible things described in Plaintiffs' <br /> Rule 26(a)(1) disclosure statement, Plaintiffs may introduce: <br /> 1. Any and all additional records, reports, documents and/or <br /> information relating to additional taxes due, taxes paid, tax <br /> certificates issued, and correspondence and other documents <br /> concerning the same dated after the date of Plaintiffs' initial <br /> disclosures. <br /> 4 <br />