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is disclosed by MidCon 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, MidCon objects to such <br /> request. If, in order to respond to DMG's requests, MidCon is required to produce information <br /> that also contains information which is neither relevant nor likely to lead to relevant information, <br /> MidCon 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, MidCon <br /> objects to such request. <br /> D. MidCon objects to any interrogatory or request for production to the extent that it <br /> is designed to annoy, embarrass, oppress, or unduly burden MidCon. <br /> E. MidCon objects to any interrogatory or request for production that purports to <br /> impose upon MidCon any obligation not expressly set forth in the Colorado Rules of Civil <br /> Procedure. <br /> F. MidCon has made reasonable efforts to respond to these interrogatories and <br /> requests for production to the extent that they are not objectionable, as MidCon understands and <br /> interprets such requests. If DMG subsequently asserts an interpretation which differs from <br /> MidCon's interpretation, MidCon reserves the right to supplement its responses so as to respond <br /> properly to any such different interpretations. <br /> G. To the extent that any interrogatory or request for production can be interpreted as <br /> requiring MidCon to identify or produce documents that are in the possession, custody, and <br /> control of others, and have not been made available to or otherwise not in the possession of <br /> MidCon, or are equally accessible to DMG, MidCon objects thereto. <br /> H. A partial response by MidCon to any request for production or interrogatory as set <br /> forth below is not deemed to be a waiver by MidCon of its objection thereto (if any), or to the <br /> right of MidCon to object to additional, supplemental, or further requests for production or <br /> interrogatories, or parts thereof. <br /> I. MidCon 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 /> J. MidCon incorporates each and every foregoing objection into each interrogatory <br /> or request for production separately responded to below. <br /> 2 <br />