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)

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One Dag Hammarskjold Jason L. Libou 212 909-9535 885 SECOND AVENUE NEW YORK NY 10017 NEW YORK  LOS ANGELES  FLORENCE DIR TEL jlibou@wmllp.com MAIN TEL WWW . WMLLP . COM 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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