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03/26/99 19:15 FAX 3037962777 BURNS FIGA & WILL la003/017 <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 thepending 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 Board of County Commissioners' requests, MidCon is <br /> required to produce information that also contains information which is neither relevant nor <br /> likely to lead to relevant information, MidCon reserves the right to produce a redacted copy of <br /> 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 /> P. 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 Board of County Commissioners subsequently asserts an <br /> interpretation which differs from MidCon's interpretation, MidCon reserves the right to <br /> supplement its responses so as to 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 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 Board of County Commissioners,MidCon objects thereto. <br /> H. A partial response by MidCon to any requests for production or interrogatory as <br /> set 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 incorporates each and every foregoing objection into each interrogatory <br /> or request for production separately responded to below. <br /> INTERROGATORIES <br /> INTERROGATORY NO. 1: Identify each person who answered or assisted in <br /> answering or was consulted in answering each of these discovery requests, and indicate the <br /> specified answer or response for which the person answered, assisted, or was consulted. <br /> 2 <br />