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General Objections <br />A. MCR objects to any interrogatory or request for production to the extent it seeks <br />information which is subject to any privileges including, but not limited to, the attorney- client <br />privilege and the attorney -work product doctrine. In the event any privileged information is <br />disclosed by MCR in this response, such disclosure is inadvertent and does not constitute a <br />waiver of any privilege. <br />B. To the extent that any interrogatory or request for production may be construed as <br />calling for information not relevant to the subject matter involved in the pending action, or is not <br />reasonably calculated to lead to the discovery of admissible evidence, MCR objects to such <br />request. If, in order to respond to DMG's requests, MCR is required to produce information that <br />also contains information which is neither relevant nor likely to lead to relevant information, <br />MCR reserves the right to produce a redacted copy of the information. <br />C. To the extent that any interrogatory or request for production may be construed as <br />overly broad, unduly burdensome or expensive, cumulative, vague and/or ambiguous, MCR <br />objects to such request. <br />D. MCR objects to any interrogatory or request for production to the extent that it is <br />designed to annoy, embarrass, oppress, or unduly burden MCR. <br />E. MCR objects to any interrogatory or request for production that purports to <br />impose upon MCR any obligation not expressly set forth in the Colorado Rules of Civil <br />Procedure. <br />F. MCR has made reasonable efforts to respond to these interrogatories and requests <br />for production to the extent that they are not objectionable, as MCR understands and interprets <br />such requests. If DMG subsequently asserts an interpretation which differs from MCR's <br />interpretation, MCR reserves the right to supplement its responses so as to respond properly to <br />any such different interpretations. <br />G. To the extent that any interrogatory or request for production can be interpreted as <br />requiring MCR to identify or produce documents that are in the possession, custody, and control <br />of others, and have not been made available to or otherwise not in the possession of MCR, or are <br />equally accessible to DMG, MCR objects thereto. <br />H. A partial response by MCR to any request for production or interrogatory as set <br />forth below is not deemed to be a waiver by MCR of its objection thereto (if any), or to the right <br />of MCR to object to additional, supplemental, or further requests for production or <br />interrogatories, or parts thereof. <br />I. MCR objects to the compound and multi -part nature of many of the <br />interrogatories which results in far more than the maximum number of interrogatories allowed. <br />2 <br />