Free Motion to Compel - District Court of Delaware - Delaware

Case 1:04-cv-01282-JJF Document 118-11 Filed O4/17/2006 Page 1 0f 3
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Case 1:04-cv-01282-JJF Document 118-11 Filed 04/17/2006 Page 2 of 3
AES Puerto Rico LP v. Alstom Power, Inc. Joseph F. Nair Volume 1
Page 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
AES PUERTO RICO, L.P. *
Plaintiff *
v. * CIV. NO. 04e1282—JJF
ALSTOM POWER, INC. *
Defendant * Pages 1 ~ 98
videotaped deposition of Joseph F. Mair, C.P.A.
Baltimore, Maryland
Thursday, April 6, 2006
Reported by: Kathleen R. Turk, RPR—RMR
4 / 6 / 2 0 0 6
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Case 1:04-cv-01282-JJF Document 118-11 Filed 04/17/2006 Page 3 of 3
AES Puerto Rico LP V. Aistom POWQI, IHC. Joseph F. Mai? vaiume i
Page 87
l currently as you sit here in this office?
2 A No.
3 Q Will you produce those documents to AES
4 Puerto Rico?
5 MR. VITTORIA: Objection.
6 It‘s our position that it's his
7 not —— it's not his place to decide whether those
8 documents are produced or not, but you're retained
9 by Qber Kaler.
N A If I'm instructed to by Qber Kaler, I
ll will.
U Q Umh—humh.
B Were you ever told by Qber Kaler to keep
M your doc —— any documents that you reviewed?
15 A No.
M Q Were you ever told to gather documents
U for production?
m A No.
N Q When were you told —— when did you
N receive this phone call telling you to come to
21 this deposition today?
4/6/2006
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