APPENDIX 16

• Jurisdiction: Colorado

APPENDIX 16

Comment: This form of a Rule 30(b)(6) notice of deposition concerns a single-family home and focuses on the construction of the home's moisture barriers. The underlying claims included claims for both property damage and bodily injury arising from exposure to allegedly toxic mold.

DISTRICT COURT, [name] COUNTY, COLORADO [address]	▲ COURT USE ONLY ▲
Plaintiffs: Homeowners Defendants: Builder-Vendor, Subcontractor 1, Subcontractor 2, Subcontractor 3, Subcontractor 4, Subcontractor 5
Attorneys for Plaintiffs: Lawyer: Law Firm: Address: Telephone: Email:	Case Number: Div.:
NOTICE OF RULE 30(b)(6) DEPOSITION (Defendant Builder-Vendor)

THE PEOPLE OF THE STATE OF COLORADO:

TO: Builder-Vendor, through its designated officer, director, managing agent, or other person who consents to testify on its behalf to the following subject matters in accordance with C.R.C.P. 30(b)(6):

1. The terms and conditions of any and all written and oral agreements pursuant to which you performed work and any other services relating to the site preparation, construction, or repair of [street address of Plaintiffs' home] ( the "Home").

2. The negotiations leading up to and the performance of any and all written and oral agreements to which you were a party and concerning all work and any other services relating to the site preparation, construction, or repair of the Home.

3. The nature and scope of all work you performed, and any other services or materials you supplied, relating to the site preparation, construction, or repair of the Home.

4. All building codes and ordinances, standards of practice, standards of care, and industry customs you attempted to comply with, if any, regarding all work you performed, and any other services or materials you supplied, relating to the site preparation, construction, or repair of the Home.

5. The manufacturer's use and/or application specifications for all materials, products, or goods used and/or supplied by you or on your behalf as part of any materials, products, or goods supplied relating to the site preparation, construction, or repair of the Home, if any, which material, product, or good was incorporated into, attached to, or became a part of the Home.

6. The nature and extent of any supervision given by you to any work you performed, or others performed on your behalf, and any other services or materials you supplied, or others supplied on your behalf, relating to the site preparation,

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