Ruby Ranch Internet Cooperative Association
c/o Oppedahl & Larson LLP
P.O. Box 5088
Dillon, CO 80435-5088
970-468-6600
carl@rric.net
By email ttymkovich@halehackstaff.com
and fax 303-592-8710
Timothy M. Tymkovich
Hale Hackstaff Tymkovich & ErkenBrack LLP
1675 Broadway, Suite 2000
Denver, CO 80202
January 6, 2002
Re: Coop's second round of discovery
Dear Mr. Tymkovich:
These discovery requests are being served
on the 13th, meaning your response would be due on the
23rd or 24th. That date, however, is of course after the
date for our prefiled direct testimony, witness list, and exhibit list, all of
which are due on the 17th. We invite you to respond to discovery
early, prior to the 17th, so as to permit us enough time to include
anything in our direct testimony, witness list, and exhibit list, that may
result from your discovery responses. Of course such an early response on your
part would be purely voluntary so far as we are aware. Otherwise our direct
testimony, witness list, and exhibit list will necessarily be served and filed
with a statement that they are subject to change depending on what we receive
from you in response to our second round of discovery requests.
Very truly yours,
Carl Oppedahl, Board member
Ruby Ranch Internet Cooperative Association