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II . INTERROGATORIES <br /> Instructions <br /> Pursuant to Rule 33 of the Colorado Rules of Civil Procedure, <br /> defendants submit to you the following interrogatories to be <br /> answered under oath, in writing, separately, in the fullest detail <br /> possible and in accordance with the definitions and instructions <br /> set forth herein. The answers shall be signed by the person <br /> making them, and a copy of the answers, together with your <br /> objections, if any, shall be served on counsel for defendant no <br /> later than 30 days after the service of these Interrogatories . <br /> You are under a duty seasonably to supplement your response <br /> with respect to any interrogatory directly addressed to: <br /> a. The identity and location of persons having knowledge of <br /> discoverable matters; and <br /> b. The identity of each person expected to be called as an <br /> expert witness at trial, the subject matter of which he or she is <br /> expected to testify, and the substance of his or her testimony. <br /> In addition, you are under a duty to amend a prior response <br /> if you obtain information on the basis of which you know that the <br /> response was incorrect when made, or that the response, though <br /> correct when made, is no longer true, and the circumstances are <br /> such that a failure to amend the response is, in substance, a <br /> knowing concealment. <br /> Interrogatories <br /> 1 . Please identify yourself and identify each and every <br /> person with whom you consulted, upon whom you relied, shared <br /> information with, or who otherwise constituted a source of <br /> information for you in connection with the preparation of your <br /> answers to these Interrogatories. <br /> 2 . Identify each and every employee, representative, <br /> officer, or agent of the Division with knowledge of the <br /> performance bond and deed of trust referenced in ¶ 3 of your <br /> Amended Complaint . <br /> a. For each and every person identified above state <br /> the nature and extent of such person' s knowledge of or <br /> involvement with the performance bond and deed of trust; and <br /> b. identify each and every communication between you <br /> and any other person identified above and each and every <br /> document relating to the performance bond and deed of trust . <br /> 3 - <br />