Free Letter - District Court of Delaware - Delaware

Case 1 :07-cv-00392-SLR Document 27 Filed 10/22/2007 Page 1 of 3
Salih Hall
SBI # 104141
Delaware Correctional Center W p
1181 Paddock Road
Smyrna, Delaware 19977 WTE @ E fi M I "
r ’ ri "`Ka lt’
A October 17, 2007 if ij; OCT 2 Q GO ii. I
li f r C L2 V _;
Stacey Xarhoulakos, Esquire gf`! _.
Deputy Attorney General i~.--.l____f}fS.ra;%§ g;
Department of Justice i` =m"""**"··~—{2·€.l:..’Qr"@}jF‘__·§
S20 N. French Street ""J
Wilmington, De 19801
RE: Hal; et aL v. Minner, et al., C.A. No. 07-CV-00392 S C A·
· Dear Ms. Xarhoulakos: . ‘
This letter comes aher doing some research, and reviewing a 9m Circuit case,
I Thom son v. Davis, 295 F.3d S90. I believe that this case is supplemental to the reply I
have recently filed to your answer involving two motions for temporary relief It appears
· thatthe Americans with Disabilities Act has been in deed interpreted to subject
traditional functions of state courts as far as the criminal law is concern, when such
practices are considered quarantine laws. This is precisely what our ADA claim entails.
We specifically claim that the state of Delaware has in effect quarantine the plaintiffs, ·
and many other similarly situated criminal defendants who suffer from chemical
dependency under the declaration of habitual offender and its finding of incorrigibility,
on the basis of our disease, when adequate treatment opportunities have not been
provided.
By copy of this letter to The Honorable Susan L. Robinson I am supplementing
my reply to include the above cited case when considering our motions pending before
the court.
Contrary to your response the complaint in this action raises significant issues .
under the ADA concerning chemical dependency as a newly categorized disease of the
brain. The Plaintiffs merely seek an opportunity at treatment, and are open to some
discussion pertaining to how that can be achieved. I urge you to be open to such a `
possibility. None of us are serious offenders and have simply acted in accordance with
the disease of which we suffer. As pointed out by you in your response, I had treatment
and made substantial progress until a chemically induced relapse brought me back into
the system. This, I believe is some evidence that treatment can work, and we should at
least be given the opportunity before being discarded.

case 1 :07-cv-00292-énjia `iE>5¢I]EéEi`2?m`T¤ia'|éd—1'o7E2EcHj? Page 2 or a -
PAGE TWO (2)
RE: LETTER TO STACEY XARHOULAKOS
DATED: OCTOBER 17, 2007
ln any event, please review the case in conjunction with the reply that has been
sent under separate cover. A copy is also provided to the clerk for inclusion into the
. record. ”
_ mcerely, '
·· Salih Hall I
Xc: Honorable Susan L. Robinson
Clerk of District Court i
Plaintiffs - _ `
{ile '

Case 1:07-cv-00392-SLR Document 27 Filed 10/22/2007 Page 3 of 3
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