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III. <br /> IDENTIFICATION OF PERSONS, DOCUMENTS, AND TANGIBLE THINGS <br /> Identification of other Persons, Documents, <br /> and Tangible Things <br /> The parties shall identify all additional persons who might be called as <br /> witnesses as well as additional documents and tangible things to be introduced at trial, not <br /> otherwise disclosed pursuant to Rule 26(a)(1), not later than June 14, 1999. <br /> IV. <br /> DISCOVERY SCHEDULE <br /> The parties currently believe that discovery in excess of the limitations set forth in <br /> Rule 26(b)(2), COLO. R. CIV. P., including depositions and written discovery, will not be <br /> necessary in this case. To the extent practicable, all depositions will be conducted jointly by <br /> the parties. <br /> A. MCR's' Discovery <br /> MCR agrees to comply with the following discovery schedule unless otherwise <br /> ordered by this Court: <br /> 1. Initial interrogatories, requests for production of documents, and <br /> requests for admissions to DMG and Pitkin County shall be served no <br /> later than March 5, 1999. <br /> 2. One set of follow-up interrogatories, requests for production of <br /> documents, and requests for admissions to DMG and Pitkin County <br /> shall be served no later than April 26, 1999. <br /> 3. Depositions of DMG's and Pitkin County's Representatives shall occur <br /> no later than July 9, 1999. <br /> 4. Depositions of two (2) other witnesses shall occur no later than July 9, <br /> 1999. <br /> 5. Depositions of expert witnesses shall occur no later than July 30, 1999. <br /> 4 <br />