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Es <br /> <br />"Describe," "describe in detail" or "description" when <br /> <br />I <br />I <br />I <br /> <br />used in reference to a factual situation or allegation, means to <br />state'with particularity all facts known to you connected with, <br />bearing upon or relating in any way to the matters of which the <br />inquiry is made. <br /> <br /> INTERROGATORIES <br /> <br />IINTERROGATORY NO. 1: Describe in detail the basis for <br />the allegation in paragraph 5 of the Complaint that "90% of local <br />I government aid distributed according to M.S'A. 477A.011, et. seq. is <br /> <br />I <br />i a <br /> nd <br /> <br />i the <br /> <br />based upon and determined by formula distributions under predecessor <br />statutes," identifying with particularity the formula distributions <br /> <br /> predecessor statutes referred to therein. <br /> <br /> INTERROGATORY NO. 2: Describe in detail the basis for <br /> <br /> allegation in paragraph 6 of the Complaint that "M.S.A. <br /> <br />I477A.011, et. seq., incorporates and perpetuates inequities from <br />past local government aid statutory formulas which results in <br /> <br /> continuing disproportionate allocations of local government aid to <br /> <br /> the City of Ramsey and precludes sufficient adjustment for change of <br />i circumstances." Identify with particularity: (a) the alleged <br /> <br />Iinequities from past local government aid statutory formulas; <br /> <br /> (b) the resulting continuing disproportionate allocations of local <br /> <br /> government aid to the City of Ramsey; and (c) the change of <br /> <br />! <br />i <br /> <br />circumstances and "sufficient adjustment" therefor that is <br />precluded. <br /> <br />--3-- <br /> <br /> <br />