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November 16, 2005
VIA FACSIMILE AND FIRST-CLASS MAIL
Jeb Boatman, Esquire
Williams & Connolly LLP
725 Twelfth Street, N.W.
Washington, D.C. 20005
Rc: AES Puerlo Rico, LP v. ALSTOM Power Inc. .
Civil Action N0. 04-1282··JJF 1
Dear Jeb:
We are in receipt of your e-mails dated November 14, and 16, 2005 regarding the
documents located in ALSTOM’s Windsor office. ,
ALSTOM could not disagree more with the assertion made in your November 14 e-mail
that Judge Farnans Order denying AES's Motion to compel "contemplates" requiring ALSTOM
to produce documents to AES for a second time. The Order contains no such language. Indeed,
Judge Faman expressly noted in his Order that ALSTOM spent many thousands of dollars in
making the documents in question available to AES. AES simply chose not to hilly avail itself
ofthe opportunity to review or copy those documents.
That being said, ALSTOM would be willing to provide AES with another opportunity to
review ALSTOM's documents on the condition that AES agree to reimburse ALSTOM for all
costs and fees associated with that second review. The fees would include not only those
incurred during the actual production, but also those incurred as a result of the need to have
ALSTOM's attorneys travel to Windsor prior to AES’s arrival to prepare the documents for
production. The costs would include all travel, lodging and food expenses incurred during both
time periods. Payment would be required within 30 days of invoicing.
Please let me know proposal is acceptable to AES.
Sincerely,
Anthony F. Qaida
AFV
cc: ALSTOM Power, Inc.
James E. Edwards, Jr., Esq.
Michael A. Schollaert, Esq.
776677
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