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Case 3:02-cv-01725-AWT Document 22-3 Filed 10/23/2003 Page1 of3
UNITED STATES BANKRUPTCY COURT
DISTRICT OF DELAWARE
JUDGE PETER J. WALSH 824 MARKET STREET
VWLMWGTON,DE19801
(302)252-2925
October 16, 2003
Abid Qureshi
Akin Gump Strauss Hauer & Feld LLP
590 Madison Avenue
New York, NY 10022-2524
Natalie M.K. Devooght
Sidley Austin Brown & Wood LLP
Bank One Plaza
10 S. Dearborn Street
Chicago, IL 60603
Alan Shapiro
Trial Attorney, Tax Division
U.S. Department of Justice
P.O. Box 55
Washington, D.C. 20044
Re: United States v. State Street Bank & Trust Co.
Adv. Proc. No. 01-4605
Dear Counsel:
As a follow up to my ruling of October 1, 2003 regarding
in camera review of privileged documents and in response to Mr.
Qureshi’s October 9, 2003 transmittal letter and Ms. DeVooght’s
October 14, 2003 transmittal letter this is my· ruling on the
production of those documents.
With one exception, I find the documents delivered by Mr.
Qureshi on behalf of the Debtor contain information, including

Case 3:02-cv-01725-AWT Document 22-3 Filed 10/23/2003 Page 2 of 3
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recapitalization strategies, consistent with the scenario I
postulated on the record at the October 1, 2003 hearing (see
transcript pp. 43-44) regarding the first Chapter 11 case being a
first step to the tax avoidance result sought to be effected by the
plan in the second Chapter 11 case. Consequently, for the reasons
stated on the record at the October 1 hearing, I am directing that
all of the identified documents be turned over to Mr. Shapiro
pursuant to his discovery request, except the document identified
as “Log 3, Item 81.” That document addresses matters which I find
completely irrelevant to the issue at hand.
With respect to the documents produced by Ms. Devooght on
behalf of Allstate Insurance Co., I would first observe that it is
not apparent to me that any of these documents constitute attorney-
client communications or attorney work product. Indeed, I conclude
that the first two documents could not possibly be deemed attorney-
client communications or attorney work product since both of them
simply deal with financial determinations to write down Allstate
Insurance Co.’s investment in the cable company. With respect to
the third and fourth. documents, for the reasons stated above
regarding the two-step reorganization scenario, I believe they
should also be produced. Thus, the four identified documents
should be produced.

Case 3:02-cv-01725-AWT Document 22-3 Filed 10/23/2003 Page3of3
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I assume that counsel will forthwith deliver copies of
the subject documents to Mr. Shapiro.
Very truly yours,
/O-JK Mk
Peter J. Walsh
PJW:ipm
cc: Peter J. Duhig, Esq.
Francis A. Monaco, Jr., Esq.
Peter W. Benner, Esq.
Virginia W. Guldi, Esq.
Joe Handlon, Esq.
Guy Neal, Esq.