Plaintiffs' Notice of Motion and Motion for Summary Judgement

    JOEL R. REYNOLDS = 

JACQUELINE W N K g-13%-9i 
NATURAL RESOURM.S DEFENSE COUNCIL 

617 S. Olive Street, Suite 1210 
Los Angeles, CA 90014 
(213) 892-1500 

JANE PERKINS 
NATIONAL HEALTH LAW PROGRAM 

2639 S. La Cienega Blvd. 
Los Angeles, CA 90034 
(213) 204-6010 

SUSAN SPELLETICH 

KIM CARD 
LEGAL AID SOCIETY OF ALAMEDA COUNTY 
1440 Broadway, Suite 700 
Oakland, CA 94612 
(415) 451-9261 

BILL LANN LEE 
KEVIN S. REED 

NAACP LEGAL DEFENSE AND EDUCATIONAL FUND, INC. 

315 W. 9th Street, Suite 208 
Los Angeles, CA 90015 
(213) 624-2405 

Attorneys for Plaintiffs 
(Additional counsel on following page) 

UNITED STATES DISTRICT COURT 
NORTHERN DISTRICT OF CALIFORNIA 

ERIKA MATTHEWS, et al., Civ. No. C-90-3620 EFL 

Plaintiffs, CLASS ACTION 
  

vs. PLAINTIFFS’ NOTICE OF 

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) 
) 

) 
) MOTION AND MOTION FOR 
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) 
) 
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) 

KENNETH KIZER, SUMMARY JUDGMENT 

Defendant. 
Date: June 21, 1991 
Time: 10:00 a.m. 

    
  

 



  

  

  

MARK D. ROSENBAGIM 

ACLU rounpaT1 oor SOUTHERN CALIFORNIA 

633 South Shattfo Place 
Los Angeles, CA 90005 
(213) 487-1720 

EDWARD M. CHEN 

ACLU FOUNDATION OF NORTHERN CALIFORNIA 

1663 Mission Street, Suite 460 
San Francisco, CA 94103 
(415) 621-2493 

  

   



  
  

TO DEFENDANTS AND THEIR COUNSEL OF RECORD; 

PLEASE TAKE NOTICE that on June 21, 1991, at 10:00 a.m., 

or as soon thereafter as counsel can be heard in the above- 

entitled court, located at 450 Golden Gate Avenue, San Francisco, 

California, the plaintiff class will move the Court for an order 

entering partial summary judgment pursuant to Rule 56 of the 

Federal Rules of Civil Procedure in favor of said plaintiffs. 

This motion is made on the grounds that there is no genuine issue 

as to any material fact and that plaintiffs are entitled to 

judgment as a matter of law. 

: This motion is based on this Notice of Motion and Motion; 

the Memorandum of Points and Authorities in support of said 

Motion; the supporting exhibits, declarations and deposition 

extracts; the Statement of Undisputed Material Facts; the 

[Proposed] Order; the pleadings, records, and files in this 

action; and such oral and written evidence as may be produced at 

the hearing. 

Dated: May 23, 1991 Respectfully submitted, 

Natural Resources Defense Council 
National Health Law Program 
Legal Aid Society of Alameda Co. 

NAACP Legal Defense and Educational 

Fund, Inc. 

ACLU of Southern California 

ACLU of Northern California 

so et Lot en 
  

ne Perkins 

J Attdrneys for Plaintiffs 

  

  

 



  

  

  

  

4 CERTIFICATE OF serv ily 

I, Jane Perkins, declare: 

I am over the age of 18 years and not a party to the 

within action. My business address is: 2639 S. La Cienega Blvd., 

Los Angeles, California 90034. 

On May 2.3 , 1991 I served the within NOTICE OF MOTION AND 

MOTION FOR PARTIAL SUMMARY JUDGMENT AND MEMORANDUM OF POINTS AND 

AUTHORITIES, STATEMENT OF UNDISPUTED MATERIAL FACTS, EXHIBITS, AND 

[PROPOSED] ORDER IN SUPPORT OF PLAINTIFFS’ MOTION FOR PARTIAL SUMMARY 

JUDGMENT on defendants by depositing same with Federal Express at Los 

Angeles, California, in a sealed, postage-paid envelope, addressed 

as follows: 

Harlan E. Van Wye 
Deputy Attorney General 
Department of Justice 
2101 Webster Street 
Oakland, California 94612-3049 

Linda Jane Slaughter 
State of California 
Department of Health Services 
Office of Legal Services 
714 "P" Street, Room 1216 
Sacramento, California 95814 

Executed this 2%d day of May, 1991, at Los Angeles, 

California. 

I declare under penalty of perjury that the foregoing is 

true and correct. 

  

Jane Perkins