Free Answering Brief in Opposition - District Court of Delaware - Delaware

Case 1:04-cv-01282-JJF Document 108-7 Filed O4/07/2006 Page 1 of 3
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Case 1:04-cv-01282-JJF Document 108-7 Filed 04/07/2006 Page 2 of 3
LAW OFFICES
WILLIAMS 8 CONNOLLY LLP
725 TWELETH STREET, NW.
D. EDWARD BENNETT WILLIAMS (|920-IQBB)
PAUL R. CONNOLLY (I922-l97B)
<2o2> 434—5263 (202) 434-5000
[email protected] FAX (202) 434-5029
January 13, 2006
Via Email & U.S. Mail
Anthony F. Vittoria, Esq.
Ober, Kaler, Grimes & Schriver
120 East Baltimore Street
Baltimore, MD 21202-1643
Re: AES Puerto Rico, LP v. ALSTOM Power, Inc.
Dear Tony:
A small number of boxes will be available at the plant on Tuesday,
January 16, 2006 for ALSTOM’s review. Please let me know when you would like to
have your copy service pick up the documents for copying.
Also, there are a number of outstanding discovery issues on ALSTOM’s
part that I would appreciate you addressing at your earliest convenience. First,
AES-PR still has not received all email for Mr. Barber — a central witness in this
litigation. Second, AES-PR still has not received ALSTOM’s electronic—document
privilege log. Third, AES-PR has not heard from ALSTOM regarding the myriad
concerns we wrote to you about regarding ALSTOM’s hardcopy privilege log.
Fourth, AES·PR still has not heard from ALSTOM regarding the ALSTOM control
room log that ALSTOM has failed to produce.
Finally, as you know, Mr. Gabrelli testified in his recent deposition
that he has responsive documents that ALSTOM has not made available to AES-
PR. Given Mr. Gabrelli’s centrality to this case, I am deeply troubled by that
admission. I trust that you will take all necessary steps to ensure that AES-PR has
access to those documents in short order and that you will also confirm that
ALSTOM has gathered all responsive documents for all of its others employees as
well.

Case 1:04-cv-01282-JJF Document 108-7 Filed O4/07/2006 Page 3 of 3
WILLIAMS as CONNOLLY LLP
Anthony F. Vittoria, Esq.
January 13, 2006
Page 2
Please feel free to call if you have any questions.
Sincerely, `
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Daniel D. Williams