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Case 1:04-cv-01282-JJF Document 118-2 Filed O4/17/2006 Page 1 of 3
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6 B Case 1:04-cv-01282-JJF Document 118-2 Filed 04/17/2006 Page 2 of 3
oBER|kALER
A Professional Corporation
Ober, Kaler, Grimes & Shriver James E. Edwards, Jr.
AUOIVIBVS at Law [email protected]
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120 East Baltimore Street Offices In
Baltimore, MD 21202-1643 Maryland
410—685·1120/ Fax 410-547-0699 Washington, D.C.
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March 27, 2006 V'g 8
VIA FACSIMILE & FIRST-CLASS MAIL,
Daniel D. Williams, Esquire
Williams & Connolly LLP
725 Twelfth Street, N.W.
Washington, D.C. 20005
Re: AES Puerto Rico, L.P. v. ALSTOM Power Inc.
Dear Dan:
This follows my letter to you dated March 24, 2006 in response to your
letter earlier that same day regarding expert witness discovery. ‘
Based upon the content of your letter of March 24, and in the absence of
agreed dates from AES, ALSTOM has served Notices to take the depositions of
persons who have been identified by AES as experts whose opinions may be
presented at trial. lf the witnesses are not going to appear on the dates that we
have scheduled for these depositions, please let me know immediately.
To date, we have been able to contact three of ALSTOM’s proposed
expert witnesses. Ronald Ballinger would be available for deposition on April 6,
7 or 11, 2006. Otakar Jonas would be available for deposition beginning
April 6, 2006. Marlin Anderson will be traveling out of the country the entire
week of April 3. He would not be available for deposition until April 11, at the
earliest, and April 12 would be better. We will provide you the availability of
Joseph Mair as soon as that has been determined.
Finally, ALSTOM does not have a discovery request from AES with
respect to notes, correspondence, e-mail, memoranda, photographs, and other
documents considered by its expert witnesses and, therefore, declines to
produce those materials. Please advise when similar materials for the experts
designated by AES will be available for inspection and copying in response to
Request No. 76 of ALSTOM’s First Request for Production of Documents.

r Case 1:04-cv-01282-JJF Document 118-2 Filed 04/17/2006 Page 3 of 3
oB12R|1 Daniel D. Williams, Esquire
March 27, 2006
Page 2
If you have any questions, please call • v-:
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Ja es E. Edwards, Jr.
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