Plaintiff's Agreed Motion to Approve Settlement Agreement

Working File
August 5, 1993

Plaintiff's Agreed Motion to Approve Settlement Agreement preview

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  • Case Files, Thompson v. Raiford Hardbacks. Plaintiff's Agreed Motion to Approve Settlement Agreement, 1993. ca044132-5e40-f011-b4cb-002248226c06. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/33dd6cb4-64f2-4359-9689-77391130ef13/plaintiffs-agreed-motion-to-approve-settlement-agreement. Accessed June 17, 2025.

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bh » 003 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

1.OIS THOMPSON on behalf of and * 

as next friend to TAYLOR 

KEONDRA DIXON, ZACHERY x. 

WILLIAMS, CALVIN A. THOMPSON 

and PRENTISES LAVELL MULLINS, 

No. 3-92 CV 1539-R 

Plaintiffs civil Action 

v. 
Clase Action 

BURTON F. RAIFORD, in hie 

capacity as Commissioner of 

the Texas Department of Human 

Services, 

and 

THE UNITED STATES OF AMERICA, 

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Defendants. 

AGREED MOTION TO APPROVE SETTLEMENT AGREEMENT 
  

The parties move the Court to approve the attached proposed 

settlement agreement. The parties are also filing a motion for 

the Court to approve a notice to fourteen organizations of the 

proposed settlement pursuant to Fed. R. Civ. P. 23(e). 

The parties believe that the settlement is fair, just, and 

reasonable. 

Respectfully Submitted, 

MICHAEL M. DANIEL, P.C. 

3301 Elm Street 
Dallas, TX 75226-1637 
214/939-9230 

By: 
  

Michael M. Daniel 
SBN 05360500 

Laura B. Beshara 

SBN 02261750 

ATTORNEYS FOR PLAINTIFFS 

1 

 



® PY : 

“Bill Lann Lee J 

Kirsten D. Levingston : 

NAACP Legal Defense & Educational 

Fund, Inc. 

315 West Ninth Street, Suite 308 

Log Angeles, CA 90015 

(213) 624-2405 

  

  
          

  

Jane Perkins 
National Health Law Program 

1815 H Street, N.W., Suite 705 

washington, D.C. 20006 
(202) 887-5310 

  

Lucy Billings 
Marie—Elena Ruffo 

Bronx Legal Services 
$79 Courtlandt Avenue 

Bronx, N.Y. 10451 

(718) 993-6250 
ATTORNEYS FOR PLAINTIFF-INTERVENORS 

  

Sheila Lieber 
Alina 8. Kofsky 
Steven H. Hartmann 
Attorneys, Department of Justice 

Federal Programs Branch, Civil 
Division 

901 E Street, N.W., Room 1010 
washington, D.C. 20530 
ATTORNEYS FOR DEFENDANT 

UNITED STATES OF AMERICA 

CERTIFICATE OF SERVICE 
  

This is to certify that a true and correct copy of the 

foregoing was served upon counsel for defendants by being placed 

in the U.S. mail, first class postage prepaid, on this the 

day of , 1993. 
    

  

Michael M. Daniel

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