Document 56-7
Filed 12/05/2005
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Tab F
Case 1:04-cv-01282-JJF
Document 56-7
LAW OFFICES
Filed 12/05/2005
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WILLIAMS & CONNOLLY LLP
725 TWELFTH STREET, N.W.
DANIEL D. WILLIAMS (202)434-5263 [email protected]
WASHINGTON, D. C. 20005-5901 (202) 434-5000 FAX (202) 434-5029
EDWARD BET-WETT W I L L I A M S
October 24, 2005
VIA E-MAIL AND FIRST CLASS MAIL Anthony F. Vittoria. Esquire Ober. Kaler, Grimes & Shriver 120 East Baltimore Street Baltimore, Maryland 21202-1643 Re: Dear Tonv: I have not heard back from you in response to my October 19, 2005 letter asking that Alstom either (1) agree to the deadline for completion of the parties' document productions that I proposed, November 18, or (2) propose an alternate date. Time is running short -- please let me know your position as soon as possible. With respect to Alstom's production of paper documents, your October 12 letter to me states that, except as noted, Alstom does not have any "other personal files in any Ober Kaler office." That statement does not address my inquiry - whether the paper documents Alstom is making available to AES-PR in its Windsor document repository now includes all responsive paper documents, including personal files, for each of the persons Alstom identified in its interrogatory responses as having information relating to the subject-matter of this lawsuit. By the end of this week, please answer that question directly so that we can proceed to review Alstom's paper documents without making multiple trips to Windsor. Finally, we received a supplemental production of electronic documents from you at the end of last week. According to my records, Alstom has not yet produced the electronic files of the following persons it identified in its interrogatory responses: AES Puerto Rico, L.P. v. ALSTOM Power, Inc.
Case 1:04-cv-01282-JJF
WILLIAMS & CONNOLLY LLP
Document 56-7
Filed 12/05/2005
Page 3 of 3
Anthony F. Vittoria. Esquire October 24, 2005 Page 2 Mike Borden Tom Coleman Joe Corole John Corrini Vincent Costa John Ferguson John Fishburn Frank Gabrielli Ron Gratton Brett Grigsby Ernest Hartman Ray Hickey Rodney Hinds William Jarvis Kurt Johnson Hank Lachut Gary Mattice Mike McDonough Steve McNary Mike Mosley William Rice Jeff Rode Robert Thrieu Jeff Tuncay Craig Winchester Edward Zielinksi It is critical that we receive these documents in the near future so that all fact and expert discovery in this matter can be completed by March 10, 2006. We look forward to hearing from you soon.
Sincerely,
Daniel D. Williams
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