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the possession of its officers, employees,agents, servants,representatives,its attorneys,or <br /> other persons directly or indirectly employed or retained by it,or anyone else acting on its <br /> behalf or otherwise subject to its control. <br /> B. If you currently lack information to answer any interrogatory completed, <br /> please state: <br /> 1. the responsive information currently available; <br /> 2. the responsive information currently unavailable; <br /> 3. efforts which you intend to make to secure the information <br /> currently unavailable; and <br /> 4. when you anticipate receiving the information currently <br /> unavailable. <br /> C. unless otherwise indicated, these interrogatories apply to the time period <br /> beginning with Third-Party Defendant's permitting of Defendant's Coal Basin property <br /> until the conclusion of the trial in this action. <br /> D. These interrogatories are continuing; supplemental answers must be filed <br /> pursuant to COLO.R.Civ.P.26(e)between the date these interrogatories are answered and <br /> the trial of this action. <br /> E. Whenever these interrogatories request you to identify a"document,"please <br /> state or identify: <br /> 1. its date; <br /> 2. its author and signatory; <br /> 3. its addressee and all other persons receiving copies; <br /> 4. the type of document (e.g., letter, memorandum, contract, <br /> report, accounting record,etc.); <br /> 5. its title; <br /> 6. its substance; and <br /> 7. the number of pages in the complete document. <br /> L'v`ITIAL INTERROGATORIES <br /> CIVIL No.97 cv 131-3 -2- PROPOUNDED TO DMG BY MCR <br />