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03/26/99 19:16 FAX 3037962777 BURNS FIGA & WILL lj]010/017 <br /> 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 Board of County Commissioners' requests,MCR is required to <br /> produce information that also contains information which is neither relevant nor likely to lead to <br /> relevant information, MCR reserves the right to produce a redacted copy of the infonnation_ <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 Board of County Commissioners subsequently asserts an interpretation which <br /> differs from MCR's interpretation, MCR reserves the right to supplement its responses so as to <br /> respond properly to any such different interpretations- <br /> G. To the extent that any interrogatories or request for production can be interpreted <br /> as requiring MCR 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 /> MCR, or are equally accessible to Board of County Commissioners, MCR objects thereto. <br /> H. A partial response by MCR to any requests 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 incorporates each and every foregoing objection into each interrogatory or <br /> request for production separately responded to below. <br /> 2 <br />