Document 56-2
Filed 12/05/2005
Page 1 of 3
Tab A
Case 1:04-cv-01282-JJF
Document 56-2
Filed 12/05/2005
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LAW OFFICES
WILLIAMS 8 CONNOLLY LLP
725 TWELFTH STREET, N.W. ,,.,.,,-, ,, ,,,,,,,, wc DANIEL D. WILLIAMS (202)434-5263 [email protected] WASHINGTON, D. C. 20005-5901 (202)434-5000 ^ ^ ^^ EDWARD BENNETT WILLIAMS
October 19, 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 Tony: I write in response to your October 14 letter. I cannot understand why you are "baffled" that I would propose a date-certain for the parties to complete their document productions. As you know, the Court has now set a discovery cut-off date, and completion of the parties' document productions is a critical first step on the path to completion of fact and expert discovery. We intend to begin taking depositions shortly, and in order to do so, we need Alstom's complete document production. If the date I proposed for completion of paper and electronic document production, November 18, 2005, will not work for Alstom, please propose an alternate date. Your October 14 letter complains that I had previously stated that AES-PR would be making a rolling production of documents and that my October 13 letter proposed that both parties complete their document productions by November 18. We are currently preparing an interim rolling production that we will send you next week. Your letter states that Alstom is making an electronic document production "during the week of October 17, 2005," although we have not yet received it. While we look forward to receiving that next installment of Alstom's rolling production, we must insist that the parties also commit to an end-date for AES Puerto Rico, L.P. v. ALSTOM Power, Inc.
Case 1:04-cv-01282-JJF
WILLIAMS 8 CONNOLLY LLP
Document 56-2
Filed 12/05/2005
Page 3 of 3
Anthony F. Vittoria, Esquire October 19, 2005 Page 2 the production of all of their responsive paper and electronic documents so that depositions can begin. Finally, your letter states that you are "not aware of any responsive hard-copy documents that ALSTOM possesses, but has not yet produced to AES." I am not clear from that statement whether Alstom is confirming that it has now produced the personal files of each individual it identified as possessing information about this lawsuit in response to AES-PR's interrogatories. Please clarify whether Alstom has done so. Sincerely,
Daniel D. Williams
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