1998-02-19_GENERAL DOCUMENTS - C1981017 (2)

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r -- Colo 1876 GALE A.NORTON STATE OF COLORADO STATE SERVICES BUILDING Attorney General 1525 Sherman Street-5th Floor MARTHA PHILLIPS ALLBRIGHT DEPARTMENT OF LAW Denver,Colorado 80203 PhonChief Deputy Attorney General FAX (303)866-56901 OFFICE OF THE ATTORNEY GENERAL RICHARD A.WESTFALL Solicitor General February 19, 1998 Ed Mulhall Delaney & Balcomb 818 Colorado Ave P.O. Drawer 790 Glenwood Springs, CO 81602 RE: Com'rs of Pitkin County v. MCR and LaGiglia v. DMG (Civil No. 97CV 131-3, Pitkin County District Court Dear Mr. Mulhall: I have received your letter of February 16, 1998, in which you state that you intend to advise your client to count"discrete"parts of the Division's interrogatories as separate interrogatories. I disagree with your position and your description of my position as to your 56 interrogatories. The Defendants' discovery request contains 56 separately numbered interrogatories (there are two interrogatories numbered 23). Several of the first 30 interrogatories contain subparts. The Division will answer the first 30 interrogatories and will object to the rest as being in violation of the Case Management Order and Rule 26. As to the Division's discovery request,the Division's interrogatories total 30 interrogatories. Each interrogatory constitutes one interrogatory and not several as you appear to argue (although you do not set forth which ones you consider to be several interrogatories instead of one interrogatory). Each interrogatory asks the Defendants one question and states what information to include in each answer. Contrary to your argument, there are no "discrete parts" that allow you to count more than 30 interrogatories in the Division's request. Accordingly, I request that you reconsider your position and answer all 30 of the Division's interrogatories.