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F' <br /> GALE A. NORTON STATE OF COLORADO STATE SERVICES BUILDING <br /> Attorney General 1525 Sherman Street -Sth <br /> DEPARTMENT OF LAW Floor <br /> STEPHEN K. ERKENBRACK Denver, Colorado 80203 <br /> Chief Deputy Attorney General OFFICE OF THE ATTORNEY GENERAL Phone 303 866 4500 <br /> TIMOTHY M. TYMKOVICH <br /> FAX �303� 866-5691 <br /> Solicitor General February 10, 1995 <br /> VIA FACSIMILE <br /> HARD COPY TO FOLLOW <br /> Joel W. Cantrick _, .0���y`�� <br /> Pendleton & Sabian, P.C. �� <br /> 303 East 17th Avenue <br /> Suite 1000 � � <br /> Denver, Colorado 80203 <br /> RE: DMG v. Reeves, et a l. <br /> Dear Joel: <br /> I have received your response to the Plaintiff's First Set <br /> of Interrogatories, Request for Production of Documents, and <br /> Requests for Admission. The defendants have objected to numerous <br /> items in the Plaintiff's discovery request and have therefore not <br /> completely answered the request. <br /> As you are aware, discovery in this case must be completed <br /> by March 30, 1995. Please consider this letter as an effort to <br /> resolve this matter in light of C.R.C.P. 121, section 1-12 (5) . <br /> Overall, the Plaintiff objects to all of the defendants' <br /> objections and preserves the right to challenge each and every <br /> objection. The Plaintiff's entire discovery request concerns <br /> issues relevant to the case at hand, and is reasonably calculated <br /> to lead to the discovery of admissible evidence. However, as <br /> stated above, this letter is an attempt by the Plaintiff to <br /> resolve discovery issues with the defendants. The Plaintiff thus <br /> specifically states as follows and requests that the defendants <br /> comply with the Plaintiff's discovery request as provided herein <br /> by 5 p.m. , February 17, 1995: <br /> I. Interrogatories as to the individual defendants (Reeves, <br /> Robert Delaney and Diane Delaney) <br /> Interrogatory 5: By their objection, the defendants <br /> have limited their answers to the past 10 years and have refused <br /> to provide information concerning the amount and form of payment <br />