Free Letter - District Court of Delaware - Delaware

Case 1:04-cv-00910-GMS Document 85 Filed 07/11/2005 Page 1 of 2
LTL- TROUTMAN SANDERS LLP ——l—·
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FACSIMILE: 212-704-6288
Am0sAlter Direct Dial: 212-704-6247
[email protected] Fax: 212-704-5914
July 8, 2005
E L. E ®
Via FedEx
Hon. Gregory M. Sleet, U.S.D.J. INI
United States District Court
J. Caleb Boggs Federal Building U_$_ Q,$m,CT COURT
844 N. King Street DIS DELAWARE
Room 324, Lockbox 19
Wilmington, DE 19801
RE: Integrated Health Services of Cliff Manor v. THCI: 04-910 (GMS)
In re Integrated Health Services: 03-610 (GMS)
THCI v. Abe Briarwood Corp: 04 Cv. 367 (GMS)
Dear Judge Sleetz
We are New York attorneys of counsel to IHS Long Term Care, a party interested
in the three referenced related matters pending before you (the first—named a removed
State Court action, the second a Bankruptcy Court appeal, and the third a civil action
commenced in this Court, wherein we are of counsel to Abe Briarwood Corp.). We are
in receipt of a copy of the letter to you of Robert E. Grossman, Esq., dated July 7,
wherein he asks for a conference with the Court.
We certainly have no objection to a conference with Your Honor, if you think it
will be helpful in resolving matters. Alternatively, if Your Honor prefers, we would be
pleased to meet with a Magistrate Judge. We ask only for forty-eight hours’ notice of
the meeting, as interested persons are in different parts of the country.
Having said that, we find it necessaiy to respond to the suggestion in Mr.
Grossman’s letter that patient care may be in issue. Nothing could be farther from the
truth. These cases involve strictly landI0rd—tenant issues. Patient care is not implicated.
Indeed, any transition in the absence of a resolution of the issues in these lawsuits
might well create a danger to the well-being of the patients.
ATLANTA · HONG KONG · LONDON · NEw YORK • NORFOLK · RALEIGH
RICHMOND • TYSONS CORNER • VIRGINIA BEACH • WASHINGTON, D.C.
NEwYoRI<01 Iocmsvt 356634-000065

. Case 1:04-cv-00910-GMS Document 85 Filed 07/11/2005 Page 2 of 2
TROUTMAN SANDERS LLP
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Hon. Gregory NI. Sleet, U.S.D.J.
July 8, 2005
Page 2
Under a Corporate Integrity Agreement entered into by our c|ient’s ultimate
predecessor, Integrated Health Services, the facilities, from a patient-care point of view,
are under the supervision of the Office ofthe lnspector—Genera| ("OlG") of the United
States Department of Health and Human Services. They are inspected regularly by Dr.
David Jackson, an outside quality monitor engaged per agreement with the OIG. He
has consistently found that we meet or surpass all standards for patient care. We have
no objection to your contacting Dr. Jackson if you have any concern about our cIients’
outstanding patient care. He may be reached at 727-742-9467.
·-=r E i ` - *
Amos Alte a YL
Cc (via FedEx):
Robert E. Grossman, Esq.
Arent Fox PLLC
Richard W. Riley, Esq.
Duane Morris LLP
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