PLAINTIFF’S FIRST SET OF DISCOVERY REQUESTS
Plaintiff, John D. MacFarlane, by and through undersigned counsel, and pursuant to C.R.C.P. 26, 33, 34, and 36, requests the following discovery from Defendants:
DEFINITIONS
1. The term “City” refers to defendant the City and County of Denver.
2. The term “CDOT” refers to the Colorado Department of Transportation.
3. The term “Golf Course” refers to City Park Golf Course.
SERVED ONLY: February 20, 2017 11:46 PM
FILING ID: 66E680DB82F17
CASE NUMBER: 2016CV321262
4. The term “Intergovernmental Agreement” refers to the Intergovernmental Agreement between the Colorado Department of Transportation and the City and County of Denver, approved by Denver’s City Council on July 6, 2015.
6. The term “PTPH Project” refers to the City’s stormwater management project sometimes identified as the Two Basin Drainage Project or Early Action Project and now identified as the Platte to Park Hill Project.
7. The term “Storm/Wastewater Enterprise Funds” refers to the City and County of Denver Wastewater Management Enterprise Fund and the City and County of Denver Storm Drainage Enterprise Fund.
8. The term “Stormwater Construction Project” refers to the portion of the PTPH Project in the Golf Course at issue in this litigation (referred-to throughout this case and that Defendants admitted in paragraph 84 of their Answer would be cited in the Golf Course).
9. The term “Shortlist Bidders” refers to: Landscapes Unlimited, LLC; Robert Trent Jones II; Saunders Construction, Inc.; Icon Golf Studio; SEMA Construction, Inc.; and DYE Designs.
10. Words in BOLDFACE CAPITALS in the below requests are defined as follows:
a. PERSON includes a natural person, firm, association, organization, partnership, business, trust, corporation, or public entity.
b. DOCUMENT means a writing, as defined in CRE 1001 and includes the original or a copy of handwriting, typewriting, printing, photostating, photographing, and every other means of recording upon any tangible thing and
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form of communicating or representation, including letters, words, pictures, sounds, or symbols, or combinations of them.
c. ADDRESS means the street address, including the city, state, and zip code.
d. YOU OR ANYONE ACTING ON YOUR BEHALF includes each and every Defendant, Defendants’ agents, Defendants’ employees, Defendants’ insurance companies, their (referring to each of the foregoing) agents, their (referring to each of the foregoing) employees, Defendants’ investigators, and anyone else acting on Defendants’ behalf.

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Plaintiff’s First Set of Discovery Requests (00847285xE2F1D)

http://www.denverinc.org/wp-content/uploads/2017/02/Plaintiffs-First-Set-of-Discovery-Requests-00847285xE2F1D.pdf