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I <br />I <br />I <br /> <br /> INTERROGATORY NO. 12: Describe in detail the basis for the allegations con- <br />tained in paragraph 19 of the Complaint. <br /> <br />RESPONSE TO INTERROGATORY NO. 12: Rick - please supply answer. <br /> <br /> INTERROGATORY NO. 13: Identify any documents within the control or custody <br />of plaintiffs that relate to any of the allegations contained in the Complaint or were <br />used in preparation of the answers to these interrogatories. <br /> <br />RESPONSE TO INTERROGATORY NO. 13: Rick - please supply answer. <br /> <br /> INTERROGATORY NO. 14: Identify each person with whom plaintiffs have com- <br />municated concerning this lawsuit or the allegations underlying the lawsuit and identify <br />the nature, form, and date of each communication. <br /> <br /> RESPONSE TO INTERROGATORY NO. 14: Rick, what do you think about answering <br />this by submitting our correspondence which I submitted to you in my memo dated <br />March 17, 1982 or perhaps you think this is too much information? <br /> <br /> INTERROGATORY NO. 15: Identify-each person whom you expect to call as an <br />expert witness at trial in this action, and with respect to each: (a) describe the <br />professional qualifications and experience of such experts; (b) describe the su3~ject <br />matter in which such expert is intended to testify; (c) describe the substance of the <br />facts and opinions to which the expert is expected to testify; (d) provide a summary <br />of the grounds for each opinion to be given by such expert; (e) identify each report, <br />study, or analysis prepared by such expert pertaining to this litigation. <br /> <br /> RESPONSE TO INTERROGATORY NO. 15: As of the date of the submitting of this <br />.Tnt~rrogatory, this decision has not been made. .'~ <br /> <br /> <br />