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10. Identify any and all documents which were referred to or relied upon for <br /> your answer to Interrogatory 9. <br /> Response <br /> See attached Petition for Abatement and Board of County Commissioner's <br /> Resolution #98-10. <br /> 11. State the earliest period of time in which interest would have stopped <br /> accruing on taxes assessed by Pitkin County against MCR had MCR paid the taxes in a <br /> timely manner. Include the basis for your answer. <br /> Response <br /> Had MCR paid each year's taxes at anytime before the due date each year, no <br /> interest would have accrued. The due date for each tax year at issue was April 30th of the <br /> succeeding year. The basis for this answer is Colorado statutes. <br /> 12. Identify any actions that could have been taken pursuant to law on behalf <br /> of MCR but were not taken, to attempt to decrease or which would have decreased, the <br /> amount of property taxes including interest owed to Pitkin County. <br /> Response <br /> Object, calls for speculation and legal conclusions. <br /> 13. State the basis for plaintiffs' allegation, pleading, statement, belief, or <br /> contention in Plaintiffs' Reply to Defendants' Amended Answer and Counterclaim (no. <br /> 77) that defendants' claims are barred in whole or in part by applicable statutes of <br /> limitation. <br /> Response <br /> Actions for abatement and tax protests are governed by specific statutes and <br /> specific time frames and claims made by MCR challenging taxes of the real and personal <br /> property subject to this action are subject to such time frames. <br /> 14. State the basis for the plaintiffs' allegation, pleading, statement, belief, or <br /> contention in the Plaintiffs' Reply to Defendants' Amended Answer and Counterclaims <br /> (no.78) that defendants have failed to exhaust administrative remedies. <br /> Response <br /> 4 <br />