Free Motion for Protective Order - District Court of Delaware - Delaware

Case 1:04-cv-01282-JJF Document 103-2 Filed O3/29/2006 Page 1 of 2
Exhibit 1

ase 1:04-cv-01282;JJ_F Document 103-2 Filed 03/2972006 Page 2 of 2
O B E R K A L E R ·
A Professional Corporation
Oher, Kalen Grimes & Shriver James E. Edwards, Jr.
Attorneys at Law [email protected]
4104347-7330
120 East Baltimore Street Offices In
Baltimore, MD 21202-1643 Maryland
410-685-1120 / Fax 410-547-0899 Washington, D.C.
““””“’°“""°°’“ March 22, 2006 Virgiiii
VIA FACSIMILE AND FIRST-CLASS MAIL
Daniel D. Williams, Esquire
Williams 8. Connolly LLP
725 Twelfth Street, N.W.
Washington, D.C. 20005
Re: AES Puerto Rico, LP v. ALSTOM Power Inc.
Dear Dan:
Now that both parties have completed their initial Expert Witness
Disclosures, we suggest moving to schedule depositions, starting with the non-
party expert witnesses that have been engaged specifically to develop expert
testimony in this proceeding. In contrast to the way that we have handled
depositions of fact witnesses, we also suggest that the depositions take place
either in our respective Firm’s offices or, failing that, in Wilmington. ln doing so,
at least for witnesses who are not local, only the expert, rather than two
lawyers, will be required to travel.
In the next two days, we will discuss availability with ALSTOM’s non-party
expert witnesses; we request that AES-PR do the same. I will contact you on
Friday, March 24, to see if we can agree upon a schedule for these depositions.
Finally, all documents viewed or prepared by AES-PR’s expert witnesses
are responsive to ALSTOM’s Request No. 76 in its First Request for Production
of Documents to AES-PR. Such documents, which include witnesses notes,
correspondence, electronic mail, memoranda, photographs, and the like, have
not yet been produced by AES-PR. Accordingly, we request that AES—PR
make these documents available for inspection and copying at its earliest
convenience.
If you have any questions or different suggestions about how to proceed,
please call me.
Sirgzxly yours,
Jar·%E. dwards, Jr.
JEEJr/bak K
cc: ALSTOM Power Inc.