Correspondence from Rosenbaum to Van Wye

Correspondence
August 2, 1991

Correspondence from Rosenbaum to Van Wye preview

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  • Case Files, Matthews v. Kizer Hardbacks. Correspondence from Rosenbaum to Van Wye, 1991. 414a853e-5e40-f011-b4cb-002248226c06. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/353f138e-01b9-43bb-8f99-31120e2551a6/correspondence-from-rosenbaum-to-van-wye. Accessed June 17, 2025.

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Ep 200 

  

~~) M aht ¢e AS 

Lon?P Ya 

ACLUY FOUNDATION 
OF SOUTHERN CALIFORNIA 633 South Shatto Place 

Los Angeles, California 90005 

(213) 487-1720 

FAX (215) 480-3221 

August 2, 1991 BY FAX AND EXPRESS MAIL 

Harlan E. Van Wye 
Deputy Attorney General 
2101 Webster Street, 12th Floor 
Oakland, California 94612-3049 
Fax (415) 464-4020 

Re: Matthews v. Kizer 
  

Dear Harlan: 

This confirms our telephone conversation this morning. It certainly appears that we are in 

substantial agreement as to the basis for settlement of this case. We genuinely appreciate your efforts 

and believe that settlement upon the terms we have discussed will benefit all parties. 

As we discussed, we will set aside next Friday to meet in Los Angeles with Linda and you. 

To date, we have agreed between us that the planning and technical implementation of a blood lead 

screening program for eligible children will be worked out by your experts and some of ours acting 

together. 

On the subject matter of attorneys’ fees, as I also mentioned to you, we have as of today, 

exclusive of costs and any multiplier, amassed hours we believe conservatively entitling us together 

to well in excess of $125,000. Joel stated in his letter to you that because of the special circumstances 

affecting this case we would jointly accept a fees payment of $75,000. The $50,000 counter-offer you 

have made is too low given that we have already reduced our request substantially. To eliminate 

negotiating steps that would only encumber accomplishment of the principal objective, may I very 

strongly suggest that we just split the difference at $62,500 for services to date and turn to the detail 

of the program to be developed. 1 have now spoken with attorneys for each of the other principal 

organizations litigating on behalf of plaintiffs and believe that it will be difficult to reach agreement 

on a sum below this number. Of course, all of this is contingent upon a rapid start-up of an 

acceptable program. 

Thank you again for your efforts. I look forward to hearing from you very early next week. 

Sincerely, 

Man lo, 
Mark Rosenbaum 

Se 

cc: Linda Jane Slaughter 
Joel Reynolds 
Jane Perkins 
Bill Lann Lee 

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