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Pitkin County ad valorem taxes. However, as sales occurred, past due taxes and accrued <br /> interest were paid from closing proceeds on parcels as each was sold.As to areas of dispute, <br /> the so-called Stewart Title escrow was created by Pitkin County and MCR.In two instances, <br /> there were significant differences between the Creditors'Trustee and Pitkin County.These <br /> differences, in part, led to this litigation. The principal differences involved two Tax <br /> Assessment Schedules, Nos. R007863 and P004062. Most differences were resolved by <br /> negotiation, settlement and compromise embodied in the Settlement Stipulation between <br /> Plaintiffs and MCR, dated January 28, 1998, filed with this Court, and approved by the <br /> Court by its Order entered February 23, 1998. The three unresolved issues, the so-called <br /> "reserved issues", are preserved by the Settlement Stipulation. <br /> Interrogatory No. 18. Identify any and all actions,and state the basis therefor, <br /> taken by the person(s) identified in your answers to Interrogatories 15 and 17, to address <br /> or protest past, present, or future tax assessments on personal or real property sold <br /> pursuant to MCR's liquidation plan, specifically including actions taken concerning <br /> property subject to Pitkin County taxes. <br /> Response to Interrogatory No. 18. MCR sought and obtained abatements on <br /> Tax Schedule No. R007863 for tax years 1995 and 1996. <br /> Interrogatory No. 19. Identify any and all documents which were referred to <br /> or relied upon to support the actions, and basis therefor, for the actions specified in your <br /> answer to Interrogatory 18 to address or protest past,present,or future tax assessments on <br /> personal or real property sold pursuant to MCR's liquidation plan. <br /> Response to Interrogatory No.19. Petition for Abatement filed by MCR with <br /> Pitkin County, dated December 11, 1997. <br /> Interrogatory No. 20. State the basis for the allegation, pleading, statement, <br /> belief or contention in the Defendants' Amended Answer and Counterclaims (no. 85) and <br /> in the Third-Party Complaint(no. 36) that it is impossible for MCR to make an accounting <br /> to Pitkin County as requested in the County's complaint(nos.3I-38),or for the Court in the <br /> above-captioned case to make a correct distribution of escrowed funds without having an <br /> accounting by DMG. <br /> Response to Interrogatory No. 20. Please refer to statements and allegations <br /> made in the pleadings and liquidation PLAN provisions that DMG may properly be paid <br /> only the amount required for reclamation according to the reclamation plan and DMG is <br /> required to negotiate with the Creditors' Trustee to establish the amounts required. <br /> Additionally,the liquidation PLAN,as alleged by Defendants in their amended answer and <br /> MCR RESPONSES TO <br /> CIVIL No.97 Cv 131-3 -1 7- DMG INITIAL DISCOVERY <br />