Joint Motion for Continuance

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Impact area
- Economic Justice
Topic
- Healthcare
Matter
- Thompson v. Raiford
Case
- Thompson v. Raiford
U.S. state
- California
Collection
- Case Files
Taxonomy
Identifier
- cdb92809-5d40-f011-b4cb-0022482c18b0

Cite this item

Case Files, Thompson v. Raiford Hardbacks. Joint Motion for Continuance, 1993. cdb92809-5d40-f011-b4cb-0022482c18b0. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/77d9fcd3-fd28-4b58-b406-7d27884c3c4d/joint-motion-for-continuance. Accessed November 02, 2025.

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    15:01 002 

® » 2-15-92 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

  

I0IS THOMPSON on behalf of and 

as next friend to TAYLOR KEONDRA 
DIXON, ZACHERY X. WILLIAMS, 
CALVIN A. THOMPSON and PRENTISS 

LAVELL MULLINS, 

Plaintiffs, 

and 

PEOPLE UNITED FOR A BETTER 
OAKLAND, et al., 

Plaintiff-intervenors, Civ. A. No. CA3-92-1539-R 

Ve. 

BURTON F. RAIFORD, in his 
capacity as Commissioner of 
the Texas Department of Human 
Services, 

and 

THE UNITED STATES OF AMERICA, 

Defendants. 

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JOINT MOTION FOR CONTINUANCE 

Plaintiffs, plaintiff-intervenors, defendant United States of 

America and defendant Burton F. Raiford hereby respectfully request 

the Court to continue the proceedings involving the claims against 

defendant U.S.A. and the claims against defendant Raiford set in this 

case for hearing on March 1, 1993. 

The parties believe that the major substantive issues in the case 

to be heard on March 1, 1993, including the use of the erythrocyte 

JOINT MOTION FOR CONTINUANCE -- Page 1 
  

 



  

15:01 4003 

o i 

protoporphyrin ("EP") test as a lead blood level assessment and the 

capacity of states to conduct blood lead testing for Medicaid-eligible 

children, have been resolved by an agreement in principle among the 

parties. 

The parties will keep the Court apprised as to the status of 

their negotiations, and will inform the Court as to the status of the 

negotiations by March 15, 1993, 

Respectfully submitted, 

(Xun A Rhona, Dated: February (( , 1993 
Michael M. Daniel 
Laura B. Beshara 

Michael M. Daniel, P.C. 
3301 Elm Street 

Dallas, Texas 75226-1637 

(214) 939-9230 

(213) 939-9229 (Fax #) 

  

ATTORNEYS FOR PLAINTIFFS 

JOINT MOTION FOR CONTINUANCE -- Page 2 
  

 



  

02-24-93 15:02 

! 

    

    

EH lots. 
Bill Lann Tee 
Kirsten D. Levingston 
NAACP Legal Defense & Educational Fund, Ine. 
318 West Ninth Street, Suite 308 Los Angeles, California 90015 (213) 624-2405 
(213) 624-0075 (Fax #) 
ATTORNEYS FOR PLAINTIFF~INTERVENORS 

      
  Sheila Lieber 

Alina 8s. Kofsky 
Steven H. Hartmann 
Attorneys, Department of Justice Federal Programs Branch, civil Division 
S01 E Street, N.W., Room 1010 Washington, b.c. 20530 
(202) 514-4523 
(202) 616-8470 (Fax #) 

HS £ 

ATTORNEYS FOR DEFENDANT 
UNITED STATES OF AMERICA 

         ee Edwin N. Horne 
Assistant Attorney General 
Office of the Attorney General 
State of Texas 
P.O. Box 12548 
Capitol Station 
Austin, Texas 78711-2548 
(512) 440-4578 
(512) 447-0511 (Fax #) 

ATTORNEYS FOR DEFENDANT RATFORD 

JOINT MOTION FOR CONTINUANCE =-— Page 3 
      

    

004 
  

#L 
rep—— 

Dated: February 4 + 1993 

Dated: February 10 + 1993 

Of Counsel: 

Henry R. Goldberg, Deputy Chief Counsel for Litigation Pavid V. Peery, Attorney Office of the General Counsel Department of Health and Human 
Services 

Room 500, East Highrise 
Building 

6325 Security Boulevard 
Baltimore, MD 21207 
(410) 965-8871 
(410) 966-5187 (Fax #) 

Dated: February | lo ¢ 1993 

 



005 
  

02/24/93 15:02 

; ® 
p— 

CERTIFICATE OF SERVICE CATE OF SERVICE 
I hereby certify that on this /% day of February, 1993, a copy of the foregoing Joint Motion for Continuance, was served via 

toderertor———nd first class mail, Postage prepaid upon: 

Sheila Lieber 
Alina sS, Kofaky 
Steven H, Hartmann 
Department of Justice 
Federal Programs Branch, civil Division 
901 E Street, N.W., Room 1010 Washington, D.C. 20530 
(202) 616-8470 (Fax #) 

Bill Lann Lee 
Kirsten D. Levingston 
NAACP Legal Defense §& Educational Fund, Inc. 
315 West Ninth street, Suite 308 Los Angeles, California 90015 (213) 624-0075 (Fax 7) 

Edwin N. Horne 
Assistant Attorney General 
Office of the Attorney General 
State of Texas 
P.O. Box 12548 
Capitol Station 
Austin, Texas 78711-2548 
(512) 447-0511 (Fax #) 

8. Resto o aura B. Beshara 
  

JOINT MOTION FOR CONTINUANCE =— Page 4

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Joint Motion for Continuance

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