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• r <br /> (n) Warehouse vacinity; <br /> INTERROGATORY NO. 20: Identify all documents concerning all expenditures <br /> described in Interrogatory No. 19 above. <br /> INTERROGATORY NO. 21: Itemize by amount and date all expenditures for native <br /> seed collection for Coal Basin reclamation in 1998. <br /> INTERROGATORY NO. 22: Describe all reclamation work to be done by any person <br /> or entity in Coal Basin in 1999 irrespective of property ownership or funding source. <br /> INTERROGATORY NO. 23: Set forth all facts and identify all documents supporting <br /> the affirmative defense in your Answer to Amended Third-Parry Complaint that Third-Party <br /> Plaintiffs have failed to exhaust administrative remedies. <br /> IYTERROGATORY NO. 24: Set forth all facts and identify all documents supporting <br /> the affirmative defense in your Answer to Amended Third-Parry Complaint that the Amended <br /> Third-Party Complaint is barred in whole or in part by waiver estoppel and/or laches. <br /> INTERROGATORY NO. 25: Set forth all facts and identify all documents supporting <br /> the affirmative defense in your Answer to Amended Third-Parry Complaint that Third-Party <br /> Plaintiffs have failed to mitigate any damages. <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 County <br /> District Court lacks jurisdiction to hear all or part of the claims asserted in the Amended Third- <br /> Party Complaint. <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 /> INTERROGATORY NO. 28: Set forth all facts and identify all documents supporting <br /> the affirmative defense in your Answer to Amended Third-Parry Complaint that Third-Parry <br /> Plaintiffs' claims are barred in whole or in part by statutes of limitations. <br /> REQUEST FOR PRODUCTION OF DOCUMENTS <br /> REQUEST NO. 1: Produce all documents identified in the answers to the above <br /> interrogatories. <br /> REOUEST NO. 2: Produce all water and soil sample results from Coal Basin. <br /> REQUEST NO. 3: Produce all documents supporting the third affirmative defense in <br /> your Answer that you have fully and completely complied with the liquidation plan. <br /> 6 <br />