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District Court, County Of Pitkin, State Of Colorado
<br /> Case No. 97 CV 13 1-1
<br /> BOARD OF COUNTY COMMISSIONERS' INTERROGATORIES AND REQUESTS
<br /> FOR PRODUCTION OF DOCUMENTS DIRECTED TO MID-CONTINENT
<br /> RESOURCES, INC.,AND LOUIS M. LAGIGLIA, CREDITORS' TRUSTEE UNDER
<br /> BANKRUPTCY PLAN OF LIQUIDATION
<br /> Board of County Commissioners of Pitkin County, Colorado, et al. v. Mid-Continent Resources,
<br /> Inc., et al.
<br /> Page 2
<br /> Requests for Production of Documents within thirty (30) days of the receipt hereof and produce
<br /> during regular business hours at the office of its attorneys of record and permit the County, its
<br /> attorneys, and agents to inspect and copy or caused to be copied the documents requested herein:
<br /> DEFINITIONS
<br /> As used herein,the following terms shall have the following meanings:
<br /> 1. The words "you", "your", or "MCR" shall mean both Third-Party Plaintiffs, Mid-
<br /> Continent Resources, Inc., and Louis M. LaGiglia Creditors' Trustee under Bankruptcy Plan of
<br /> Liquidation, its present and former agents and employees and all other persons acting, or purporting
<br /> to act, on its behalf or on behalf of its predecessors.
<br /> 2. "DMG" shall mean Third-Party Defendant Division of Minerals and Geology, its
<br /> present and former agents and employees and all other persons acting, or purporting to act, on its
<br /> behalf or on behalf of its predecessors.
<br /> 3. The word "document" means all written, printed, typed, recorded or graphic matter,
<br /> facsimile transmissions, photographic matter (including prints, slides and negatives), sound
<br /> reproductions, computer files, computer hard drives, computer discs and hard copy printouts, tapes,
<br /> in-puts or out-puts, however produced or reproduced, or any other matter from which information
<br /> may obtained whether draft or final, original or reproduction, including, but not limited to,
<br /> letters, correspondence, memoranda, minutes, notes, films, videotapes, audiotapes, recordings of
<br /> any kind, transcripts, contracts, diaries, desk calendars, telegrams, telexes, wires, faxes, reports,
<br /> interoffice or inteaoffice communications, including electronic mail, whether deleted, saved or
<br /> stored, data stored and any computer media, computer runs or printouts, spreadsheets, tabulations or
<br /> materials similar to any of the foregoing, however denominated, and by whomever prepared and to
<br /> whomever addressed and non-identical copies thereof, all non-identical copies referred to or
<br /> reproductions however made of the original document which have notations, markings, comments
<br /> or other material not appearing in the original.
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