Free Motion to Strike - District Court of Delaware - Delaware

Case 1:04-cv-01282-JJF Document 148-2 Filed 10/02/2006 Page 1 of 4

Case 1:04-cv-01282-JJF Document 148-2 Filed 10/02/2006 Page 2 of 4
Volume I 5/3/2006
Page l
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
C.A. No. 04—I282—JJF
AES PUERTO RICO, L.P.
VS
ALSTOM POWER, INC.
Videotaped Deposition of: WILLIAM JARVIS,
taken pursuant to the Federal Rules of Civil Procedure
before Barbara L. Murphy, Licensed Shorthand Reporter,
License No. 305 and Notary Public within and for the
state of Connecticut, held at the offices of Cowdery,
Ecker and Murphy, 750 Main Street, Hartford,
Connecticut on March l4, 2006 commencing at 9:42 a.m.
Job No. l72947b
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Case 1:04-cv-01282-JJF Docu/_rgef{l}SLg—2I Filed 10/02/2006 Page /2 006
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1 MR. EDWARDS: Same objection. You can
2 answer.
1 THE WITNESS: Yes.
4 Q. (By Mr. Williams) Alstom is a big company,
6 correct?
6 A. Yes, it is.
7 Q. And what part of Alstom do you work for?
6 A. It's called environmental —— energy
2 environmental systems.
16 Q. And that's based here in Windsor,
11 Connecticut?
U A. That's correct.
N Q. Where does the energy and environmental
M systems unit of Alstom report?
16 A. Say again please.
16 Q. To whom does the energy and environmental
U systems unit of Alstom report?
M A. Philippe Joubert.
12 Q. And who is he?
26 A. He is the head of the energy and
21 environmental systems group.
22 Q. And where is he located?
22 A. In Paris.
24 Q. What part of Alstom does he report to?
E A. He reports to Philippe Kron, to Mr. Kron,
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1 yeah. He is the head of the company.
2 Q. And he's also in France?
2 A. Yes.
1 Q. In Paris?
5 A. Yes, right?
5 Q. Is Alstom a French owned company?
7 MR. EDWARDS: Objection. Foundation.
8 You can answer.
8 THE WITNESS: Yes.
18 Q. (By Mr. Williams) Is it owned by the French
11 government?
U MR. EDWARDS: Objection. Foundation.
B You can answer.
M THE WITNESS: I believe the French
15 government owns a portion of the stock of the company,
15 yes. 1
11 Q. (By Mr. Williams) You can put Exhibit 2
18 aside.
12 One of the duties of a project manager is
28 to keep the project within budget; is that accurate?
21 A. Yes.
m Q. Was the AES Puerto Rico project within
22 budget?
21 A. No.
25 Q. Did it make money for Alstom?
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