Free Motion to Compel - District Court of Delaware - Delaware

Case 1:04-cv-01282-JJF

Document 49-5

Filed 11/28/2005

Page 1 of 2

Tab C

Case 1:04-cv-01282-JJF

Document 49-5

Filed 11/28/2005

Page 2 of 2

LAW OFFICES

WILLIAMS 8 CONNOLLY LLP
725 TWELFTH STREET, N.W. WASHINGTON, D. C 20005-5901 JEB BOATMAN (202)434-5974
[email protected]
NOT ADMITTED [N DC
EDWARD BENNETT WILLIAMS (1920-1986) PAUL R CONNOLLY 11922-1978)

(202) 434-5000 FAX (202) 434-5029

May 11,2005

VIA E-MAIL AND FIRST CLASS MAIL Michael A. Schollaert, Esq. Ober Kaler Grimes & Shriver 120 East Baltimore Street Baltimore, Maryland 21202-1643

Re: Dear Mike:

AES Puerto Rico, L.P. v. ALSTOM Power, Inc.

As you and I discussed, Dan and I would like to inspect the 215 boxes in Windsor, Connecticut on May 19 and 20, 2005. Although we continue to have concerns that ALSTOM has not met its discovery obligations as to those documents, Dan and I would like to look at a sample of the documents to determine whether this is the case. If the bulk of the documents are indeed responsive to our requests, then Dan and I plan to review them all while we're in Windsor. In order for us to finalize our travel plans, please advise as soon as possible where specifically we should come next Thursday to view the documents, what time period each day you are willing to make the documents available, and who we should ask for. Also, please advise how you would like us to tag documents for copying and whether we should arrange to have a copy service take the documents for copying or whether you can have them copied and sent to us within three business days of our visit to Windsor. Sincerely,

Jeb Boatman cc: Daniel D. Williams, Esq. Anthony F. Vittoria, Esq.