Waterkeeper Alliance, Inc. v. Spirit of Utah Wilderness, Inc.
Filing
229
ORDER granting 228 Letter Motion to Compel. Mr. Salt is directed to respond to Plaintiff and the Court on or before July 9, 2021. (Signed by Judge Nelson Stephen Roman on 6/25/2021) (rro)
One Dag Hammarskjold
Jason L. Libou
212 909-9535
885 SECOND AVENUE
NEW YORK NY 10017
NEW YORK LOS ANGELES FLORENCE
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jlibou@wmllp.com
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FACSIMILE
212 909-9500
212 371-0320
June 24, 2021
Via PACER/ECF
The Honorable Nelson S. Román
United States Courthouse
300 Quarropas Street, Room 218
White Plains, New York 10601
Re:
6/25/2021
Waterkeeper Alliance, Inc. v. Spirit of Utah Wilderness, Inc. et al.
Civil Action No.: 10-cv-1136
Dear Judge Román:
This law firm represents the plaintiff, Waterkeeper Alliance, Inc. (“Plaintiff”), in the abovecaptioned suit.
On June 1, 2021, the Court granted the eighth letter motion filed by defendant Jeffrey Salt
(“Salt”) to extend the deadline for him to surrender to the U.S. Marshals Service due his repeated,
willful violations of this Court’s Orders from May 1, 2021 until August 1, 2021 on the express
condition that Salt provide the financial affidavit and responses to Plaintiff’s interrogatories and
document requests as required by this Court’s prior orders on or before June 22, 2021. (ECF Doc.
227, emphasis supplied). Salt has not complied with any of the requirements imposed by the Court
as a condition of the surrender date extension by completely failing to provide the financial
affidavit and responses to Plaintiff’s discovery requests.
Accordingly, Plaintiff respectfully requests that the Court reinstate the previously imposed
penalty of imprisonment and require Salt to surrender to the U.S. Marshal by no later than
Wednesday, June 30, 2021. Salt cannot be permitted to continue flagrantly disregarding this
Court’s Orders without consequence, which he will obviously continue to do unless he is
imprisoned.
Thank you for the Court’s attention to this matter.
Respectfully submitted,
WACHTEL MISSRY LLP
Jason L. Libou
Mr. Salt is directed to respond to Plaintiff and the Court on
or before July 9, 2021.
Jason L. Libou, Esq.
Dated: 6/25/2021
White Plains, NY
092485-001/00289989-1
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