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pF.CO <br /> O <br /> 1876 <br /> GALE A. NORTON STATE OF COLORADO STATE SERVICES BUILDING <br /> Attorney General 1525 Sherman Street- 5th Floor <br /> DEPARTMENT OF LAW Denver, Colorado 80203 <br /> STEPHEN K. ERKENBRACK Phone (303) 866-4500 <br /> Chief Deputy Attorney General OFFICE OF THE ATTORNEY GENERAL FAX (303) 866-5691 <br /> TIMOTHY M. TYMKOVICH <br /> Solicitor General <br /> March 13 , 1995 <br /> VIA FACSIMILE <br /> BARD COPY TO FOLLOW <br /> Joel C. Cantrick <br /> Pendleton & Sabian, P. C. <br /> 303 East 17th Avenue <br /> Suite 1000 <br /> Denver, CO 80203 <br /> RE: DMG v. Reeves <br /> Dear Joel : <br /> This letter is to confirm Judge Jones' ruling concerning my <br /> Motion to Compel and to set a time frame for compliance with the <br /> order. However, before addressing that issue, there are a few <br /> preliminary matters to be addressed. <br /> You have set the depositions of Susan Burgmaier and Erica <br /> Crosby for March 17, 1995; Michael Long' s deposition for March <br /> 28 ; and Jim Pendleton' s deposition for March 23 . You have stated <br /> that you expect that Mr. Pendleton' s deposition will only be for <br /> one-half of a day. Mr. Pendleton has informed me that he is only <br /> available until noon on March 23 . <br /> In light of the court' s rulings on my motions, I will <br /> reschedule the depositions of Diane and Robert Delaney, John <br /> Reeves, and Louis LaGiglia, which are now scheduled for the week <br /> of March 20 , 1995 . Please inform me of the dates on which these <br /> individuals are available for deposition for the week of April 3 , <br /> 1995 . <br /> As for your supplemental responses to our discovery request <br /> (one faxed March 7, 1995, at 5 : 56 p.m. and one faxed March 8, <br /> 1995, at 12 : 11 p.m. ) , these responses are inadequate in light of <br /> the judge' s ruling. In addition, there appears to be a conflict <br /> in the Defendants' responses . In the Defendants' response to <br /> Interrogatory No. 12 , the individual defendants concede that they <br /> "appeared in front of the Mined Land Reclamation Board since the <br />