Free Letter - District Court of Delaware - Delaware

Case 1:92-cv-00597-SLR Document 51 Filed 08/31/2007 Page 1 of 2
LAW OFFICES
PARKOWSKI, GUERKE & SWAYZE
PROFESSIONAL ASSOCIATION
1 16 WEsT WATER STREET
P.O. Box 598
DOVER, DELAWARE 19903
302-678-3262
F. MICHAEL PARKOWSKI FAX: 302-678-9415
I. BARRY GUERKE
DAv1n S. SWAYZE GEORGE F. GARDNER, 111
CLAY T. JESTER or COUNSEL
JEREMY W. HoMER
JOHN C. ANDRADE
MARK F. DUNKLE
WILLMM A_ DENMAN wu.MmcToN omcr;
M1cHAEL W. ARR1NcToN 800 KING STREED SUITE 203
CHRIS1-{NE p_ Scmm-Z WILMINGTON, DE 19801-0369
MICHAEL W. TEICHMAN 302·654·3300
BASIL C_ KOLLIAS FAX!
ANNE HARTNETT REIGLE
August 31, 2007
VIA ELECTRONIC MAIL USING CM/ECF
AND FIRST CLASS MAIL
Dr. Peter T. Dalleo
U.S. District Court
844 North King Street, Room 4209
Lock Box 18
Wilmington, DE 19801
RE: Salt Pond Associates, Plaintiffs, v.
United States Army Corps of Engineers, et al., Defendants
Case No.: 92-597-LON
Dear Dr. Dalleo:
Our firm represents the Plaintiff/Counter-Defendant, Salt Pond Associates (Salt Pond) in
the above matter. The Defendants/Counter-Plaintiffs are currently represented by Patricia C.
Hannigan, Assistant U.S. Attomey, and Barry F. Gale, U.S. Army Corps of Engineers. This
letter requests that the attached Stipulation to Modify Consent Decree (Stipulation) be presented
to the Court for approval. At the bottom of the Stipulation, there is a proposed order approving
the Stipulation.
Although the attached pleading is self-explanatory, it is lengthy and, therefore, it may be
helpful to relate the following background. The purpose of the stipulation is to set the stage for
terminating a Consent Decree (Decree) (Exhibit A to the Stipulation) entered into between the
parties and approved by the Court on March 30, 1994 (Docket No. 48). The Decree, among
other things, required Salt Pond to perform certain work, which now has been completed. The
Decree, at paragraph 42 (p. 18), also provided for the Court’s retention of jurisdiction until
termination of the Decree by the Court. Exhibit C to the Stipulation contains a form of motion
for terminating the case, which will be filed at some point after the Stipulation is approved.

Case 1 :92-cv-00597-SLR Document 51 Filed 08/31/2007 Page 2 of 2
Dr. Peter T. Dalleo r
Page 2
Please let me know if you have any questions or need any other information to process
the case. Thank—you for your assistance.
Yours truly,
JEREMY W. HOMER
Delaware Bar ID#04l3
J WHsar `
ezmail: [email protected]
Enclosures
cc: Patricia C. Hannigan, Esquire (W/Enclosures) (Via First Class Mail)
Barry F. Gale, Esquire (W/Enclosures) (Via First Class Mail)
Brian Blackwell, U.S. District Court (W/Enclosures) (Via First Class Mail)
F. Michael Parkowski, Esquire (W/Enclosures) 1