Free Letter - District Court of Delaware - Delaware

Case 1:04—cv—01211-I\/IPT Document 28-4 Filed 02/21/2008 Page1 0f2
EXHIBIT C

Case 1 :04-cv-0121 1-IVIPT Document 28-4 Filed 02/21/2008 Page 2}olEg1 OH
John M. LaRosa, Esguire
From: "John M. LaRosa, Esquire"
To: "'DiBianca, Margaret"'
Cc: "Neuberger, Esq. Thomas S."
Sent: Friday, February 15, 2008 1:55 PM
Attach: Order of Judgmentdoc; Order of Judgment.wpd
Subject: Tobin v. Gordon: Pension Issue and Form of Order of Judgment
Molly:
The following will memorialize our telephone conversation this aftemoon. On behalf of plaintiff, I requested that
the County recalculate his pension to reflect retirement al a Captain's rate of pay. Such a measure would not cost
the County any additional monies up front. Also, we understand that the County has done this in the past in
employment cases for other long-time police officers.
You indicated that in fairness, you indeed would address this issue with your client.
Also, regarding the form of Order of Judgment, I suggested that we use the attached draft, in which we just briefly
state the terms as contemplated in Defendants' Offer of Judgment (i.e. "$25,000 plus reasonable attorneys fees
and costs") and indicate that ultimately the amount awarded for fees and costs will be a figure approved by the
Court. If this is acceptable to all defendants, I will file it with the Court.
Please let me know defendants' response on both of these issues by Tuesday.
Thank you for your continued cooperation in resolving this matter.
Very truly yours,
I John M. LaRosa
Law Ofhce of John M. LaRosa
Two East 7th Street, Suite 302
Vwlmington, Delaware 19801-3707
(302) 888-1290
(302) 655-9329 (fax)
YIQ/VW.L8R0§8L8W.CO_@ (website)
2/2 l/2008