Laserfiche WebLink
In producing the documents requested herein,plaintiffs shall furnish all documents in <br /> their possession, control or accessible to plaintiffs, or in the possession, control or accessible to <br /> plaintiffs' attorneys, investigators, representatives, agents, employees or anyone acting in their or <br /> their attorney's behalf,unless any document is claimed to be privileged from discovery. <br /> This request for production is continuing. In the event any documents come into <br /> plaintiffs' possession, control or become accessible to plaintiffs, or come into the possession, <br /> control or become accessible to plaintiffs' attorneys, investigators, representatives, agents, <br /> employees or anyone acting in their or their attorney's behalf after the filing of plaintiffs' <br /> responses to these requests for production, which documents are within the scope of any request <br /> for production, said additional documents shall be furnished to the attorneys for the third-party <br /> defendant promptly pursuant to Colo.R.Civ.P. 26(e). <br /> For each interrogatory, request for admission or request for production to which the <br /> plaintiffs object based on a claim of privilege, the objection should state the basis on which <br /> privilege is claimed, and if the objection is to a request for production, it should identify the <br /> document(s) which are withheld pursuant to the privilege. <br /> For each interrogatory, request for admission or request for production to which the <br /> plaintiffs object based on a claim that it is burdensome, the objection should state in detail the <br /> efforts needed to comply with the discovery request including, but not limited to: <br /> (1) The location and number of files and/or documents needed to be searched; <br /> (2) The location and number of persons needed to be interviewed; <br /> (3) The number of hours required for compliance; and <br /> 6 <br />