Free Answering Brief in Opposition - District Court of Delaware - Delaware

Case 1:04-cv-01282-JJF

Document 56-10

Filed 12/05/2005

Page 1 of 3

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Case 1:04-cv-01282-JJF

Document 56-10

Filed 12/05/2005

Page 2 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE
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AES PUERTO RICO, L.P., Plaintiff,
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Civ. No. 04-1282-JJF

ALSTOM POWER, INC., Defendant.

DECLARATION OF JEB BOATMAN I, JEB BOATMAN, declare as follows: 1. I am an attorney at Williams & Connolly LLP, and I represent AES Puerto Rico,

L.P. ("AES-PR") in the above-captioned matter. This Court has granted my motion for admission pro hac vice. This declaration is based on my personal knowledge except where otherwise noted. 2. To date, AES-PR has collected well over 75,000 electronic documents (hundreds

of thousands of pages of documents) to review for production. 3. AES-PR is formatting, reviewing, and producing those documents as part of an

agreed-to rolling production of electronic documents. To date, AES-PR has produced over 80,000 pages of electronic documents. 4. On a number of occasions, ALSTOM has complained about the metadata

included with AES-PR's electronic documents and has demanded that the parties' e-discovery liaisons meet to discuss the complaints. AES-PR believes that ALSTOM's complaints reflect a misunderstanding of several technological issues relating to electronic-document discovery.

Case 1:04-cv-01282-JJF

Document 56-10

Filed 12/05/2005

Page 3 of 3

AES-PR has offered to help facilitate a meeting between the parties' e-discovery liaisons to discuss ALSTOM's complaints. ALSTOM has never followed up to hold the meeting. I declare under penalty of perjury that the foregoing is true and correct. Executed on this 5th day of December, 2005, at Washington, D.C.

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