1999-04-05_GENERAL DOCUMENTS - C1981017

• Permit No: C1981017
• IBM Index Class Name: GENERAL DOCUMENTS
• Doc Date: 4/5/1999
• Doc Name: Responses
• From: Burns, Figa & Will, P.C.
• To: Cheryl Linden
• Permit Index Doc Type: General Correspondence
• Media Type: D
• Archive: No

04/05/99 17:21 FAX [phone] BURNS FIGA & WILL Z003
General Objections
A. MCR objects to any interrogatory or request for production to the extent it seeks
information which is subject to any privileges including, but not limited to, the attorney- client
privilege and the attorney -work product doctrine_ In the event any privileged information is
disclosed by MCR in this response, such disclosure is inadvertent and does not constitute a
waiver of any privilege.
B. To the extent that any interrogatory or request for production may be construed as
calling for information not relevant to the subject matter involved in the pending action, or is not
reasonably calculated to lead to the discovery of admissible evidence, MCR objects to such
request. If, in order to respond to DMG's requests, MCR is required to produce information that
also contains information which is neither relevant nor likely to lead to relevant information.
MCR reserves the right to produce a redacted copy of the information.
C. To the extent that any interrogatory or request for production may be construed as
overly broad, unduly burdensome or expensive, cumulative, vague and/or ambiguous, MCR
objects to such request.
D. MCR objects to any interrogatory or request for production to the extent that it is
designed to annoy, embarrass, oppress, or unduly burden MCR.
E. MCR objects to any interrogatory or request for production that purports to
impose upon MCR any obligation not expressly set forth in the Colorado Rules of Civil
Procedure.
F. MCR has made reasonable efforts to respond to these interrogatories and requests
for production to the extent that they are not objectionable, as MCR understands and interprets
such requests. If DMG subsequently asserts an interpretation which differs from MCR's
interpretation, MCR reserves the right to supplement its responses so as to respond properly to
any such different interpretations.
G. To the extent that any interrogatory or request for production can be interpreted as
requiring MCR to identify or produce documents that are in the possession, custody, and control
of others, and have not been made available to or otherwise not in the possession of MCR, or are
equally accessible to DMG, MCR objects thereto.
H. A partial response by MCR to any request for production or interrogatory as set
forth below is not deemed to be a waiver by MCR of its objection thereto (if any), or to the right
of MCR to object to additional, supplemental, or further requests for production or
interrogatories, or parts thereof.
I. MCR objects to the compound and multi -part nature of many of the
interrogatories which results in far more than the maximum number of interrogatories allowed.
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