Free Motion for Leave to File - District Court of Delaware - Delaware

Case 1:04-cv-01282-JJF Document 119-6 Filed O4/19/2006 Page 1 012
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Case 1:04-cv-01282-JJF Document 119-6 Filed O4/19/2006 Page 2 of 2
LAW OFFICES
VVILLIAMS 8 CONNOLLY LLP
725 TWELFTH STREET, N.W.
(202) 434-5262. (202) 434-5000
[email protected] FAX (202) 434-5029
April 18, 2006
VIA E-MAIL AND FIRST CLASS MAIL
Anthony F. Vittoria, Esquire
Ober, Kaler, Grimes & Shriver
120 East Baltimore Street
Baltimore, Maryland 21202-1643
Re: AES Puerto Rico, L.P. v. ALSTOM Power, Inc;
Dear Tony:
After receiving ALSTOM’s reply brief in support of its motion for
sanctions last Friday, AES—PR sought to re-confirm that it had produced copies of
its quarterly EPA reports transmitting CEMS data. During the course of that
review, AES—PR discovered that, although the EPA quarterly reports it possesses
had been designated for copying, they inadvertently had not been copied and
produced. Please be advised that those reports are now available for ALSTOM’s
review and inspection at my office. You should be aware that AES—PR does not
believe it possesses copies of two of the EPA quarterly reports, one for the fourth
quarter of 2003 and one for the first quarter of 2005.
Please have your copy service contact me to arrange pick-up. If you
would like to discuss this matter further, feel free to call me at your convenience.
Sincerely, q
/ » A
Daniel D. Williams