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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 6 <br /> 3. These discovery requests are continuing and additional or supplemental information <br /> responsive to these discovery requests which becomes known to or comes into the possession, <br /> custody or control of Third-Party Plaintiffs is to be provided to the undersigned counsel. <br /> 4. If any document requested was in existence or available to you but no longer is in <br /> existence or available to you, then, with respect to each such document, please: <br /> (a) Describe the nature of the document(letter, memorandum, etc.). <br /> (b) State the date of the document. <br /> (c) Identify the person or persons who sent and received the original and copies <br /> of the document. <br /> (d) State in as much detail as possible the contents of the document. <br /> (e) State the circumstances under which the document was lost, destroyed or <br /> other became unavailable. <br /> 5. If you object to any Interrogatory or Request for Production or contend that you are <br /> entitled to withhold from production any document requested herein on the ground that it requests <br /> information that is privileged, or falls within the work product doctrine, or on some other grounds, <br /> then, with respect to each of those discovery requests please: <br /> (a) State the nature of the claim of privilege or doctrine you claim is applicable <br /> and the basis for your claim. <br /> (b) Identify the type of document affected (e.g., letter, memorandum, etc.) or the <br /> subject matter of the Interrogatory. <br /> (c) Identify and produce all documents related to the claim or privilege. <br />