APPENDIX 15

• Jurisdiction: Colorado

APPENDIX 15

DISTRICT COURT, [name] COUNTY, COLORADO [address]	▲ COURT USE ONLY ▲
Plaintiffs: Homeowners Defendants: Developer, Builder, and Principals
Attorneys for Defendants: Lawyer: Law Firm: Address: Telephone: Email:	Case Number: Div.:
DEFENDANTS' INITIAL WRITTEN DISCOVERY REQUESTS

Defendants, by and through their attorneys, [Law Firm], hereby submit the following initial set of written discovery requests to Plaintiffs pursuant to C.R.C.P. 26, 33, and 34:

I. INSTRUCTIONS

A. Please answer the following in writing, under oath, within thirty-five (35) days in accordance with Rules 26, 33, and 34 of the Colorado Rules of Civil Procedure.

B. Before each Answer or Response given to these discovery requests, please re-type each Interrogatory or Request. In turn, we will extend the same courtesy to you in discovery responses prepared by this party.

C. An answer or other appropriate response must be given to each Interrogatory.

D. As a general rule, within 35 days after you are served with these Interrogatories, you must serve your responses on the asking party and serve copies of your responses on all other parties to the action who have appeared.

E. Each answer must be as complete and straightforward as the information reasonably available to you permits. If an Interrogatory cannot be answered completely, answer it to the extent possible.

F. If you do not have enough personal knowledge to fully answer an Interrogatory, say so, but make a reasonable and good faith effort to get the information by asking other persons or organizations, unless the information is equally available to the asking party.

G. Whenever an Interrogatory may be answered by referring to a document, the document may be attached as an exhibit to the response and referred to in the response. If the document has more than one page, refer to the page and section where the answer to the Interrogatory can be found.

H. Whenever an address and telephone number for the same person are required in more than one Interrogatory, you are required to furnish them in answering only the first Interrogatory asking for that information.

I. If you consider any document or communication to be privileged, then, with regard to each such document or communication, describe the document or communication generally, explain fully the basis for the claimed privilege, identify the author of the document or person making the communication and all signatories to the document, and identify the custodian of the original and all copies of the document. Retain these documents separately in the event court review of the asserted privilege is subsequently required. In the event any documents requested to be produced have been destroyed, identify all such documents as particularly as possible, and state when, by whom, and under what circumstances they were destroyed.

J. If any document requested to be identified was at one time in existence, but is no longer in existence, identify the document, and for each document so identified specify the nature of the document, the type of information contained therein, the day upon...