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Response: Objection: Judge Craven has ordered in the Third Revised Case <br /> Management Order that all motions for partial summary judgment shall be filed on or before <br /> thirty days after completion of discovery. All other pretrial motions shall be filed no later than <br /> sixty days prior to the date set for trial of this matter. Interrogatory 23 requests explanations <br /> and documents which are covered by the Court's motions deadlines. The information <br /> requested in this interrogatory is not required to be disclosed until the deadlines set forth in <br /> the Court's Order. <br /> INTERROGATORY NO. 24: Set forth all facts and identify all documents supporting <br /> the affirmative defense in your Answer to Amended Third-Party Complaint that the Amended <br /> Third-Party Complaint is barred in whole or in part by waiver estoppel and/or laches. <br /> Response: See Objection to Interrogatory No. 23. <br /> INTERROGATORY NO. 25: Set forth all facts and identify all documents supporting <br /> the affirmative defense in your Answer to Amended Third-Party Complaint that Third-Party <br /> Plaintiffs have failed to mitigate any damages. <br /> Response: See Objection to Interrogatory No. 23. <br /> INTERROGATORY NO. 26: Set forth all facts and identify all documents supporting <br /> the affirmative defense in your Answer to Amended Third-Party Complaint that the Pitkin <br /> County District Court lacks jurisdiction to hear all or part of the claims asserted in the <br /> Amended Third-Party Complaint. <br /> Response: See Objection to Interrogatory No. 23. <br /> INTERROGATORY NO. 27: Set forth all facts and identify all documents supporting <br /> the affirmative defense in your Answer to Amended Third-Party Complaint that Third-Party <br /> Plaintiffs' claims are barred in whole or in part by the Colorado Governmental Immunity Act. <br /> Response: See Objection to Interrogatory No. 23. <br /> INTERROGATORY NO. 28: Set forth all facts and identify all documents supporting <br /> the affirmative defense in your Answer to Amended Third-Party Complaint that Third-Party <br /> Plaintiffs' claims are barred in whole or in party by statutes of limitations. <br /> Response: See Objection to Interrogatory No. 23. <br /> 10 <br />