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~FEB-I5-GI 09;22AM ~CFRDI,~DAV1$, 6RAHAMI 8 STUBBS 3038931378 • ' ~ Davis Graham s:Stubbs LLP February 1~, 2001 Via Facsimile (804 293 2811) Walton D. Morris At[omey-at-Law 1901 Pheasant Lane Chazlottesville, VA 22901 T-291 P 02/193 F-863 II l I ll I II I II IIII III Via Facsimile (303 866 3558) Stephen Brown Assistant Attorney General 152 Sherman Street, Floor 5 Denver, CO 80203 Re: Proposed Schedule for Depositions -- Notice of Violation No. CV-2000-009 Gentlemen: As you know, we have depositions in the above-referenced matter scheduled for the week of Mazch 5, 2001. We have agreed to lunit depositions to experts. At present, Basin has submitted reports from two experts, John Rold and Bob Thompson. The Tatums have submitted an expert report from Cazlton Gerity. I understand that the Tatums may submit a report from an appraiser, subject to appropriate leave. I also understand that the Division may submit the propose a rebuttal witness, as might the other parties. I believe that I will need one full day to conduct the deposition of Mr. Geriry. I suspect that Mr. Morris will need about the same time for the deposition of Mr. Rold. If the Tatttms propose an appraiser as an expert, I would not expect my deposition of that expert to take more than a couple hours. I do not know how much time Iv1r. Morris might need with Mr. Thompson, but imagine that it will be less than the amount of time required of Mr. Rold. Further, I do not know how much time Mz. Brown anticipates spending with any of these witnesses. Wehave apre-hearing conference on Mazch 9, 2001. For the sake of efficiency, I propose that that heating be held on the morning of Mazch 9, and the we try to conduct all the depositions on March G, 7, and 8. I propose that Basin Resources tender Mr. Rold for a full clay on Mazch 6, that the Tatums tender Mr. Gerity to Basin for a full day on Mazch 7, and that we schedule the depositions of Mr. Thompson and [he Tatums appraiser, if any, on March 8. Mr. Gerity and perhaps Mr. Rold may need to be available to the Division on that day as well. If there aze additional expert witnesses, or if the State plans extensive deposition time with any of these witnesses, then we will need to plan to begin on March 5. Mr. Rold may have some scheduling difficulties on March 5, but we'll addresses those if necessary. Mr. Thompson has Scot W. nndersan 303 892 7383 ScotAnaersonEtlgslaw.com 1550 Se~enteenm Street - Swte SOU Dense[ Ceio~aao A^202 ~ 303 892 4400 6.303 893 t 379 wNW.09:Iaw.fOm