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b. Identify each and every communication and each and <br /> every document relating to such circumstances . <br /> 28 . With respect to each and every expert whom you expect to <br /> call as an expert witness at trial, provide the following: <br /> a. His or her name, address, telephone number and <br /> occupation; <br /> b. The subject matter on which he or she is expected <br /> to testify; <br /> C. The substance of the facts and opinions to which he <br /> or she is expected to testify; <br /> d. A summary of the grounds for his or her each and <br /> every opinion; and <br /> e. A copy of each and every document upon which he or <br /> she relied, or which he or she consulted, in formulating his or <br /> her opinion. <br /> 29 . With respect to each and every person whom you expect to <br /> call as a witness at trial, provide the following: <br /> a. His or her name, address, telephone number and <br /> occupation; and <br /> b. The subject matter on which he or she is expected <br /> to testify. <br /> III . DOCUMENT REQUEST <br /> Instructions <br /> 1 . All requested documents shall be produced for inspection <br /> and possible copying at the offices of Pendleton & Sabian, P.C. , <br /> 303 East 17th Avenue, Suite 1000, Denver, Colorado 80203-1263 , <br /> within 30 days of the date of service hereof, or at such other <br /> time and place as counsel may agree. <br /> 2 . Please label each produced document with the number of <br /> the production request to which it corresponds. <br /> 3 . If you had, at any time, possession, custody or control <br /> of a document requested herein, and such document is not presently <br /> in your possession, custody or control, please describe the <br /> document and the date of and circumstances surrounding its loss, <br /> destruction or separation from your possession, custody or <br /> control . <br /> - 10 - <br />