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16. Identify any and all documents which were referred to or relied upon to decide when <br /> to pay and in what amount to pay property taxes on each piece of real or personal property sold <br /> pursuant to MCR's liquidation plan. <br /> 17. Identify the person(s) who made the decision(s) on behalf of the Creditors' Trust as <br /> to actions to take to address past, present, or future tax assessments on personal or real property <br /> sold pursuant to MCR's liquidation plan, including the person(s) who made decisions on whether <br /> to protest tax assessments or seek abatements as to interests assessed by Pitkin County. If you <br /> identify more than one person,please state the dates on which each person made the decisions <br /> and the transactions on which each person made decisions, and the authority under which such <br /> person made the decisions. <br /> 18. Identify any and all actions, and state the basis therefor, taken by the person(s) <br /> identified in your answers to Interrogatories 15and 17, to address or protest past, present, or <br /> future tax assessments on personal or real property sold pursuant to MCR's liquidation plan, <br /> specifically including actions taken concerning property subject to Pitkin County taxes. <br /> 19. Identify any and all documents which were referred to or relied upon to support the <br /> actions, and basis therefor, for the actions specified in your answer to Interrogatory 18 to address <br /> or protest past, present, or future tax assessments on personal or real property sold pursuant to <br /> MCR's liquidation plan. <br /> 20. State the basis for the allegation, pleading, statement, belief or contention in the <br /> Defendants' Amended Answer and Counterclaims (no. 85) and in the Third-Party Complaint (no. <br /> 36) that it is impossible for MCR to make an accounting to Pitkin County as requested in the <br /> 12 <br />