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_ _ r Case 1 :04-cv-01282;JJF Document 103-4 Filed 03/29/2006 Page 2 of 3
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A Professional Corporation
Uber, Kaler: Grimes &Sirrirr¤r James E. Edwards. Jr.
Attorneys at Law . [email protected] -
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120 East Baltimore Street Diliuss In
Baltimore, MD Zl202-1643 Maryland
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“"“â€Â·Â°"“’i°°'“ March 27, 2006 “"¤*“"
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, LP. 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. lt 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 ALSTOl\/l’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 l\/lair 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.
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Daniel D. Williams, Esquire
March 27, 2006
Page 2
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