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Case 1:05-cv-00809-***-IVIPT Document 14 Filed 12/O2/2005 Pagmitvaot {Bimini Mme

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December l, 2005
VIA FACSIMILE AND FEDERAL EXPRESS
Frank Ogundare
Southern Delaware Center for Children & Families
l424 Shiloh Church Road
Laurel, DE l9956
Frank Ogundare
Southern Delaware Center for Children & Families
l8907 Unit 4 Maranatha Way _
Bridgeville, DE l9933
Re: Withdrawal of Legal Representation
Dear Mr. Ogundare:
The purpose of this letter is to notify you that, as of this date, Feldesrnan Tucker
Leifer Fidell LLP ("Finn") will no longer represent Southern Delaware Center for
Children & Families (“SDCC&F") in connection with the suspensionftermination of its
federal Head Stan assistance. This includes the representation of SDCC&F in the United
States District Court for The District of Delaware in Civil Action 05-809 filed by the _
i United States Attorney on behalf of the plaintiff, United States Department of Health and
Human Services. As you are aware, our representation of SDCC&F was contingent upon
SDCC&F securing local counsel and said local counsel filing a Pro Hac Vice Motion for
the Firm’s admission in the District Court of Delaware to represent you in this matter.
The court was willing to allow the Finn to represent you, without the Pro Hac Vice
motion. However, as you know, our role in this matter was to consult and assist local
counsel. We have been unable to communicate with local counsel. Therefore, we must
withdraw as SDCC&F counsel. As you know the coun has allowed the Firm to withdraw
from this case, but is not extending the time for you to file a response.
Attached you will find documents received from the Assistant United States
Attomey in this case. You will note that the following deadlines are approaching:
i 2001 LStreet, N.W. 1 Second Floor l W'ashing1un,D.C Z0036—4910I (202] 466459601 Telefax {202) 293-8103 l www.feldesn1ant1id
Case 1:05-cv-00809-***-IVIPT Document 14 Filed 12/O2/2005 Page 2 of 2
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Frank Ogundare
December 1,2005
Page 2 of 2
• Responsive Brief- December 5, 2005 at 12:00 P.M.(Noon);
• Plaintiffs Reply Brief ~ December 6, 2005
• Hearing on Temporary Restraining Order — December 7, 2005;
lf you are able to contact local counsel, you may have him contact us and we will .
take such steps as are reasonable to familiarize counsel with the status of the proceedings.
I f you have any questions, you can reach me, Ted Waters, or Robert Graham at
(202) 466-8960.
Sincerely,
Leonard Lucas
Enclosures 1
cc: The Honorable Kent A. Jordan w/o Enclosures