Waterkeeper Alliance, Inc. v. Spirit of Utah Wilderness, Inc.
Filing
255
ORDER granting 254 Letter Motion to Stay re: 254 LETTER MOTION to Stay arrest warrant addressed to Judge Nelson Stephen Roman from Joseph A. Vita dated March 15, 2022. The arrest warrant will be stayed until March 23, 2022 to allow Plaintiff time to respond to Mr. Salt's request. Mr. Salt is also directed to indicate in writing what, if any, documents and responses to interrogatories he has provided to Plaintiff on or before March 22, 2022. (Signed by Judge Nelson Stephen Roman on 3/15/2022) (ate)
Case 7-10-cv-01136-NSR
Document 254
Filed in NYSD on 03/15/2022
Page 1 of 2
JOSEPH A. VITA
ATTORNEY AT LAW
52 Irenhyl Avenue
Port Chester, New York 10573
Telephone 914-939-5401
Joev63542@aol.com
VIA ECF
March 15, 2022
Hon. Nelson S. Roman
United States District Court Judge
United States Courthouse
300 Quarropas Street
White Plains, New York 10601
Re:
3/15/2022
Waterkeeper Alliance, Inc. v. Spirit of Utah Wilderness, Inc., 10 CV 1136 (NSR-LMS)
Dear Judge Roman:
I am writing as counsel for Jeffrey Salt with respect to the Court’s order (Doc 253) dated
1/14/22. In this order the Court granted an extension in the stay of the arrest warrant until March
16, 2022, to allow Mr. Salt time to complete compliance with the Court’s previous orders with
respect to document production and interrogatory response. Because of Mr. Salt’s continuing
medical problems and worsening health conditions as described in detail and documented in the
attached email and exhibits, I am requesting on Mr. Salt’s behalf a further extension in the stay
to produce the outstanding documents until July 10, 2022. Mr. Salt’s chronic medical problems
have made it impossible for him to timely comply with all the order requirements regarding
document production.
Attached are the following exhibits in support of his application for an extension based
upon good cause:
Exhibit A Positive COVID – 19 test results
Exhibit B Email of Jeffrey Salt dated March 15, 2022, describing his medical conditions
Exhibit C Additional Medical records.
As noted in prior requests for a stay, Mr. Salt has complied with the primary
requirements of the judgment (ECF 100, 160) insofar as he submitted proof through counsel that
he ceased infringing on Plaintiff’s trademarks (ECF 195) and publicly posted the Statement
required by the 2d contempt order (ECF 160, 225).
Arresting Mr. Salt and confining him to a federal detention facility will in no way
facilitate his ability to comply with any requirement of producing documents; it would have just
the opposite effect. Given that he has ceased using Waterkeeper Marks and provided a detailed
Case 7-10-cv-01136-NSR
Document 254
Filed in NYSD on 03/15/2022
Page 2 of 2
financial affidavit and supporting documentation and considering his documented medical
ailments I urge the Court to exercise its discretion to grant the requested further stay.
In summary, I am requesting that the Court grant the applications contained in this letter
together with such other and further relief as the Court deems appropriate in the interest of
justice.
Thank you for considering this request.
Respectfully submitted,
/S/ Joseph A. Vita
Joseph A. Vita
Cc:
Jeffrey Salt via EMAIL
The arrest warrant will be stayed until March 23, 2022
to allow Plaintiff time to respond to Mr. Salt's request.
Mr. Salt is also directed to indicate in writing what, if
any, documents and responses to interrogatories he has
provided to Plaintiff on or before March 22, 2022.
Dated: March 15, 2022
White Plains, NY
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