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DISTRICT COURT, PITKIN COUNTY, COLORADO <br /> Case No. 97 CV 131-3 <br /> MOTION FOR PROTECTIVE ORDER AND FOR STAY OF DISCOVERY <br /> Board of County Commissioners of Pitkin County, Colorado, and Thomas Carl Oken, Pitkin <br /> County Treasurer, <br /> Plaintiffs, <br /> V. <br /> Mid-Continent Resources, Inc. and Louis M. LaGiglia, Creditors' Trustee under Bankruptcy <br /> Plan of Liquidation, <br /> Defendants & Third-Party Plaintiffs and MidCon Realty, LLC, <br /> Third-Party Plaintiffs; <br /> v. State of Colorado, Department of Natural Resources, Division of Minerals and Geology, <br /> Board of County Commissioners of Pitkin County, Colorado, <br /> Third-Party Defendants. <br /> Third-Party Defendant, the Division of Minerals and Geology("Division"), moves for <br /> a protective order and to stay further discovery in the above-captioned case for the following <br /> reasons: <br /> 1. On March 24, 1999, Geoffrey Anderson, counsel for all three Third-Party <br /> Plaintiffs, faxed a Notice of Deposition of Division employee Steven Renner. Exhibit 1. The <br /> date proposed for the deposition was April 9, 1999, with the understanding that if Mr. Renner <br /> was unavailable at that time, the deposition could be rescheduled. <br /> 2. On April 1, 1999, Mr. Anderson requested further responses from the Division to <br /> Third-Party Plaintiffs' discovery request. Exhibit 2. <br /> 3. On April 1, 1999, the Division placed in overnight mail a Motion to Dismiss <br /> Certain Claims of Mid-Continent Resources, Inc. and the Creditors' Trustee. On April 7, <br />