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Interrogatory No. 29. State the basis for the allegation, pleading, statement, <br /> belief or contention in Defendants'Amended Answer and Counterclaims(nos.127-131)that <br /> Tax Assessment Schedule No. R007863 is invalid and that this schedule is an improper <br /> collection of this tax assessment. <br /> Response to Interrogate No.29. MCR objects to this interrogatory. All issues, <br /> other than the three "reserved issues' (none of which are involved in the foregoing <br /> interrogatory), between Pitkin County and MCR are disposed of by the Settlement <br /> Stipulation, dated January 28, 1998, the subject matter of a motion to approve the same, <br /> dated January 29, 1998, and the Court's Order of approval entered February 23, 1998; <br /> therefore, with the Court's approval, all issues other than the "reserved issues" are <br /> dismissed with prejudice and no longer a part of this litigation. The interrogatory is not <br /> relevant; further it calls for a legal conclusion. <br /> REQUEST FOR PRODUCTION OF DOCL:�fENTS <br /> Defendants' "general response" to all document production requests. All docu- <br /> ments not heretofore furnished DMG by MCR are available for inspection at the office of <br /> MCR's counsel during normal business hours, upon reasonable advance notice and at <br /> time(s) and date(s) mutually convenient to counsel. Copying may be done by DMG by <br /> making arrangements and paying for such copying,as well arranging for a paralegal or staff <br /> person from MCR's counsel's office to accompany documents to be reproduced, by a <br /> copying firm in Glenwood Springs, Colorado. <br /> Document Request No. 1. Produce each and every document identified by <br /> defendants in defendants' response to Interrogatory No. 3. <br /> Response to Document Request No. 1. See MCR's general response at the <br /> beginning of this discovery section. <br /> (a) A conformed copy of the M&E KING CONTRACT is Answer Exhibit <br /> 1 attached to MCR's amended answer and previously furnished to counsel for DNIG. <br /> (b) The Bankruptcy Court "Order Authorizing Debtor [MCR] to Employ <br /> Equipment Liquidators and to Obtain Credit Secured by Senior Lien",entered August 13,1992 by <br /> Honorable Patricia A. Clark, is MCR Exhibit No. 2 enumerated in the Rule 26(a)(1) <br /> Disclosures filed by MCR and the Creditors' Trustee and dated October 7, 1997. <br /> MCR RESPONSES TO <br /> CIVIL No.97 Cv 131-3 -23- DMG INITLAL DISCOVERY <br />