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DISTRICT COURT, PITKIN COUNTY, COLORADO
<br /> Case No. 93 CV 201, Division 2
<br /> DEFENDANTS' FIRST SET OF INTERROGATORIES, REQUEST FOR PRODUCTION
<br /> OF DOCUMENTS, AND REQUESTS FOR ADMISSIONS TO PLAINTIFF
<br /> DIVISION OF MINERALS AND GEOLOGY, DEPARTMENT OF NATURAL RESOURCES,
<br /> STATE OF COLORADO,
<br /> Plaintiff,
<br /> V.
<br /> JOHN A REEVES; ROBERT DELANEY; DIANE DELANEY; AND MID-CONTINENT
<br /> MINERALS CORPORATION,
<br /> Defendants.
<br /> Pursuant to Rules 26, 33 , 34, and 36 of the Colorado Rules of
<br /> Civil Procedure, defendants, by and through their attorneys,
<br /> Pendleton & Sabian, P.C. , submit to you the following
<br /> interrogatories, request for production of documents, and requests
<br /> for admissions to be answered under oath, in writing, in the
<br /> fullest detail possible and in accordance with the definitions and
<br /> instructions set forth below.
<br /> I . DEFINITIONS
<br /> 1 . Communication. As used herein, the term "communication"
<br /> means any oral or written utterance, notation, or statement of any
<br /> nature whatsoever, by and to whomsoever made, including, but not
<br /> limited to, correspondence, conversations, dialogues, discussions,
<br /> interviews, consultations, agreements, and other understandings
<br /> between or among two or more persons, whether by telephone or in
<br /> person.
<br /> 2 . Division. As used herein, the term "Division" means
<br /> plaintiff Division of Minerals and Geology, Department of Natural
<br /> Resources, State of Colorado, and each of its agents,
<br /> representatives, attorneys and investigators acting on its behalf .
<br /> 3 . Document . As used herein, the term "document" means any
<br /> medium upon which intelligence or information can be recorded or
<br /> retrieved and includes, without limitation, any book, pamphlet,
<br /> periodical, letter, memorandum (including any memorandum or report
<br /> of a meeting or conversation) , invoice, bill, order form, receipt,
<br /> financial statement, accounting entry, diary, calendar, summary,
<br /> bulletin, circular, instruction, notebook, telex, TWX, telegram,
<br /> cable, report, record, contract, agreement, study, handwritten
<br /> note, draft, working paper, chart, paper, print, laboratory
<br />
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