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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 3
<br /> 4. The word "concerning" includes referring to, alluding to, responding to, relating to,
<br /> connected with, commenting on, in respect of, about, regarding, discussing, showing, addressing,
<br /> describing, mentioning, reflecting, analyzing,constituting, pertaining to or evidencing.
<br /> 5. The word "communication" means any contact between two or more persons,
<br /> agencies or companies and shall include without limitation written contact by such means as letters,
<br /> electronic mail, memoranda, telegrams, telexes, facsimile transmissions, or by any document and
<br /> oral contact by such means as face-to-face meetings and telephone conversations.
<br /> 6. The word "person(s)" means all entities and agencies and includes without limiting
<br /> the generality of the foregoing, natural persons, joint owners, associations, companies, partners,
<br /> joint ventures, corporations, trusts, and estates, governmental agencies or subdivisions.
<br /> 7. The word "identify", with respect to a document, means list the document type
<br /> (letter, memorandum, notes, etc.), date, title, author, recipient, summary of subject matter, and
<br /> current custodian.
<br /> 8. The word "identify", when used with respect to any non-written communication,
<br /> means to provide:
<br /> (a) the names of the natural persons making and receiving the communication;
<br /> (b) their respective principals or employers at the time of the communication;
<br /> (c) the date, manner, and place of the communication; and
<br /> (d) the substance of the communication.
<br /> The word "identify" when used with respect to any natural person or individual, means to
<br /> provide:
<br /> (a) the person's full name;
<br />
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