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04/05/99 17:30 FAX 3037962777 BURNS FIGA & WILL Z018 <br />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 product 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 />