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DISTRICT COURT, PITKIN COUNTY, COLORADO <br /> Case No. 93CV201 <br /> PLAINTIFF' S FIRST SET OF INTERROGATORIES, REQUEST FOR PRODUCTION <br /> OF DOCUMENTS, AND REQUESTS FOR ADMISSION TO DEFENDANT JOHN A. <br /> REEVES <br /> DIVISION OF MINERALS AND GEOLOGY, DEPARTMENT OF NATURAL <br /> RESOURCES, STATE OF COLORADO, <br /> Plaintiff, <br /> V. <br /> JOHN A. REEVES; <br /> ROBERT DELANEY; <br /> DIANE DELANEY; and <br /> MID-CONTINENT MINERALS CORPORATION, <br /> Defendants. <br /> COMES NOW the Plaintiff, through its attorney, the Colorado <br /> Attorney General' s Office, and submits the following first set of <br /> interrogatories, request for production of documents, and request <br /> for admissions to Defendant John A. Reeves . <br /> Pursuant to Rules 26, 33 , 34, and 36, of the Colorado Rules <br /> of Civil Procedure, the interrogatories and requests are to be <br /> answered under oath, in writing, in the fullest detail possible <br /> and in accordance with the instructions and definitions set forth <br /> below, thirty (30) days after service on the Defendant. <br /> DEFINITIONS AND GENERAL INSTRUCTIONS <br /> A. Document . The term "document" as used herein means the <br /> original (or, when the original is not in your possession, <br /> custody, or control , a carbon or other identical copy) , and each <br /> copy of the original that contains any attachment, note, or <br /> marking not contained in or on the original, of every written, <br /> recorded, transcribed, punched, taped, filmed, or graphic matter, <br /> however produced or reproduced, including, but not limited to, <br />