First Amended Complaint; Affidavits of Barbara Wesson, Rosa Keeton, Eddie Gray; Correspondence from Lief to Allen and Miller

     [||fd12659e-3758-45e0-ac86-e9b9862cf7e7||] IN THE UNITED STA"L,S DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF INDIANA Fi L ED 

HAMMOND DIVISION JUN 1 9.1977 

FRANCIS T. GRANDYS, CLERK 
U. S. DISTRICT COURT p, 

  

BERNICE TERRY, et al., 

Plaintiff, 

Ve 

METHODIST HOSPITAL OF GARY, INC., 

An Indiana-Not-For-Profit 

Corporation, and JOSEPH CALIFANO, FIRST AMENDED 
as United States Secretary of COMPLAINT 
Health, Education and Welfare, 

Cause No. H 76-373 

Defendants, 

  

1. 

l. This is a class action for declaratory and injunctive 

relief brought by an individual representing minority residents 

of Gary, Indiana against defendants' default of their obligations 

under Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 20004 

(hereinafter Title VI) and to redress the deprivation of the 

rights of plaintiff and the plaintiff class guaranteed by the 

Fifth nk Fourteenth Amendments to the Constitution of the United 

States and the Civil Rights Act of 1871, 42 G.8.0. § 1983. 

2. Jurisdiction of the Court is invoked pursuant to 28 

U.S.C. 68 1331, 1343 and 1361. Plaintiff's claim for a declara- 

tion of rights is authorized by 28 U.S.C. §§ 2201 and 2202. 

The amount in controversy exceeds, exclusive of interest and costs, 

: the sum or value of $10,000. 

II. 

Parties Plaintiff 
  

3. Plaintiff Bernice Terry is a black resident of Gary who 

 



  

has used the facilities of Gary Methodist Hospital. She had 

required and it is likely that she will require use of hospital 

facilities, including emergency room treatment, in the future. 

Plaintiff Terry is injured and will continue to be injured by 

the segregation and discrimination in the provision of hospital 

services by defendant Methodist Hospital of Gary, Inc. 

4. Plaintiff Terry brings this action on her own and on 

behalf of all persons similarly situated. The plaintiff class 

is composed of all minority residents of Gary, Indiana who use, 

have used, or will use Gary Methodist Hospital and who are, 

have been, or will be injured by sie creation, perpetuation, 

and expansion of a segregated hospital system. The requirements 

of Rule 23 (a) and (b) (2) are satisfied: 

(1) the class represented by plaintiffs is so 

numerous that joinder of all members is impracticable; 

(ii) there are questions of law and fact common 

to all class members; 

(iii) the claims of the named plaintiffs are typical 

of the claims of class members; 

(iv) final injunctive and declaratory relief with 

respect to the class as a whole is appropriate since 

defendants have acted or refuse to act on grounds gen- 

erally applicable to the class. 

111 

Parties Defendant 
  

5. Defendant Methodist Hospital of Gary, Inc., 1s a not- 

for-profit corporation organized under the laws of the State 

of Indiana, which currently operates a 419-bed facility in the 

IE, 

 



  

City of Gary (hereinafter "Gary Methodist") and a 165-bed 

facility in Merrillville, a suburb of Gary (hereinafter 

"Broadway Methodist"). Methodist Hospital of Gary, Inc., 

is a recipient of federal funds under the Hill-Burton Act and 

the Medicare and Medicaid programs, and other federal programs. 

Methodist Hospital has received more than three million dollars 

in direct construction grants and more than eight million 

dollars in loan guarantees with interest subsidies under the 

Hill-Burton Progra, including a grant and loan guarantee for 

the construction of Broadway Methodist. As a condition for the 

receipt of all federal funds, Methodist Hospital is subject 

to the requirements of Title VI. 

6. Defendant Joseph Califano is the United States Secretary 

of Health, Education and Welfare (hereinafter HEW) and has the 

responsibility for all federal programs administered by the 

United States Department of Health, Education and Welfare. 

Defendant HEW is responsible for the administration and enforce- 

ment of Title VI pertaining to the disbursement of federal 

financial assistance to programs administered by HEW, including 

Hill-Burton grants and loan guarantees. 

iv 

Statement of Facts 
  

7. Methodist Hospital of Gary, Inc., has operated the Gary 

Methodist Hospital, located in the City of Gary, since 1923. 

8. The City of Gary is located in the northwest corner of 

the State of Indiana. It is the largest city in Lake County, 

a heavily industrialized area with a population in 1970 in excess 

of 630,000. Gary has a population of approximately 175,000, 

i TR 

 



  

53% of which is Black and 10% of which is Hispanic. 

9. On March 1, 1967, the Gary Joint Hospital Fund, Inc., 

was issued a charter by the State of alana. This organiza- 

tion was structured to combine the efforts of many people to 

enter into a cooperative fund-raising drive for the benefit 

of St. Mary Mercy Hospital and Methodist Hospital. The stated 

purpose of this fund-raising drive was to help relieve a press- 

ing bed shortage and overcrowded conditions that existed at St. 

Mary Mercy Hospital and Methodist Hospital, both of which are 

located in the City of Gary. A public subscription goal sought 

from industry, business, trust foundations and individuals, in 

the Gary hospital service area, a minimum of $3,500,000 to be 

divided between St. Mary Mercy Hospital and Methodist Hospitals. 

The stated purpose of the funds received by Methodist Hospital 

of Gary, fn. wad land oaulaliion, modernization and expansion 

of Gary Methodist Hospital. 

10. Although Methodist Hospital of Gary, Inc., received 

approximately $2,249,500.00 from the Gary Joint Hospital Fund, 

Inc., it did not undertake the majority of the renovation or 

expansion of Gary Methodist Hospital that had been the stated 

purpose of the fund drive. Instead, Methodist Hospital proceeded 

with a plan to build a Satellite Hospital on Broadway, also 

known as Route 53, south of U. 8S. 30 in Merrillville, Indiana, 

an overwhelmingly white suburb of Gary. That satellite hospital 

is now a $18 million general, short term hospital consisting of 

165 beds with capacity to expand to 600-800 beds. That facility 

was completed in December of 1975. 

11. Eighty percent of the patients treated at Gary Methodist 

dln 

 



  

® @ 

Hospital are Black and Hispanic while only 10% of the patients 

treated at Broadway Methodist Hospital are Black and Hispanic. 

Similarly, the overwhelming majority of the staff at each facil- 

ity mirrors the race of the patients served. 

12. Defendant Methodist, has by its actions over the last 

10 years, demonstrated its intent to deprive the black residents 

of the City of Gary of adequate medical services. The con- 

struction of the Broadway Methodist Hospital has had and will 

continue to have the purpose and effect of creating a hospital 

system which excludes persons from, denies them the benefit of, 

and other wise discriminates against and segregates them on the 

basis of race and national origin: 

(a) defendants located the new Broadway facility in 

an area populated overwhelmingly by whites and removed from the 

City of Gary with its concentration of blacks, Hispanics and 

elderly and handicapped persons; 

(b) defendants have assigned and otherwise employed 

personnel in the Broadway and Gary facilities on a racially seg- 

regated and otherwise discriminatory basis; 

(c) defendants have installed at the Broadway facility 

modern and critical facilities (e.g., radiation equipment for 

the treatment of cancer) which are not available at the Gary 

facility, and not accessible to the minority residents of Gary 

by public transportation. 

13. Methodist Hospital by Gary, Inc., constructed Broadway 

Methodist Hospital with a grant of $1,152,500 and a guarantee on 

a loan for $14,336,000 with an interest subsidy totalling 

$6,900,000 which it received and continues to receive from the 

 



“ N 

  

defendant HEW pursuant to Title VI of the Public Health Services 

Act, 42 U.S.C. § 291 et seqg., (hereinafter "Hill-Burton" Act). 

14. HEW approved the Hill-Burton loan and grant applica- 

tion of Methodist Hospital of Gary, Inc., to construct Broadway 

Methodist Hospital without considering whether the new hospital 

would create a segregated, dual hospital system which would dis- 

criminate against the minority residents of Ging. 

15. Methodist Hospital of Gary, Inc., submitted another 

application in 1976 for § 1122 approval and a Hill-Burton grant 

and loan guarantee for an $8,143,370 project. The majority of 

the funds in this project is to be used to expand the facilities 

of Broadway Methodist Hospital. 

16. HEW received objections from several sources to the 

approval of Hill-Burton funds for the Methodist Hospital of Gary, 

Inc. The objections specifically opposed the approval of the 

application on the grounds, inter alia, that Methodist Hospital 
  

of Gary, Inc., was operating a dual, segregated hospital system 

and was providing inferior health care to the poor and minority 

residents of Gary. In its reply to these objections, HEW admitted 

that racial segregation "is a realty;" that it relies upon the 

HSA for evaluations; and that the HSA "made no attempt to compare 

the quality of care at both institutions [Broadway Methodist 

Hospital and Gary Methodist Hospital]." 

17. HEW gave civil rights' clearance to the 1976 proposal, 

and granted the Hill-Burton application. In so doing, HEW ap- 

proved the continuation and expansion of a hospital system which 

discriminates against persons, including the named plaintiffs, 

on the basis of race, color or national origin. 

=6m 

 



  

18. Plaintiff Dbelievesthat in light of HEW's approval 

of the 1976 application over the objections of numerous residents 

of Gary, including some of the named plaintiffs and HEW's view of 

its responsibilities under controlling law, any further efits to 

seek HEW enforcement of Title VI, to protect their statutory and 

constitutional rights,would be futile. 

V. 

Causes of Action 
  

19. Defendant Methodist Hospital of Gary, Inc., is violating 

Title VI and its implementing regulations, 42 U.S.C. 1983 and 42 

C.P.R., 53.112 by: i 

(a) having engaged and engaging in policies and prac- 

tices which discriminate against and segregate persons on the basis 

of race, color, or national origin; 

(b) failing to comply with specific assurances which 

it made to HEW regarding its obligations under Title VI. 

20. Defendant HEW has violated its duties to enforce Title" 

VI, and the rights of plaintiffs and the plaintiff class by: 

(a) approving and providing federal funds for the con- 

struction of Broadway Methodist Hospital by Methodist Hospital of 

Gary, Inc., which violated and is violating Title VI and its im~ 

plementing regulations; 

(b) failing to enforce the assurances submitted by the 

Methodist Hospital of Gary, Inc.; 

(c) approving the $8.1 million loan guarantee and in- 

terest subsidy under the Hill-Burton Act; 

(d) failing to enforce the civil rights provision of 

regulations under the Hill-Burton Act, 42 C.F.R. § 53.112; 

 



  

(e) failing to enforce the site selection provision 

to civil rights' regulations, 45 C.F.R. § 80.3 (b) (3) against 

recipients of federal financial assistance, including the de- 

fendant Methodist Hospital of Gary, Inc. 

Vill 

Prayer For Relief 
  

21. WHEREFORE, plaintiff respectfully prays that this 

Court enter judgment: 

(a) declaring that the policies of Methodist Hospital 

of Gary, Inc., complained of herein violate rights secured by 

Title VI of the Civil Rights Act of*1964, 42 U.S.C. § 2000d, 

and the Civil Rights Act of 1871, 42 U.S.C. 1983; 

(b) declaring the HEW's grant of federal financial 

assistance to Gary Methodist Hospital, which discriminates against 

and segregates persons on the basis of race, color or national 

origin, violates rights guaranteed by Title VI; 

(c) enjoining Methodist Hospital of Gary from enjoin- 

ing in policies and practices which discriminate against and seg- 

regate persons on the basis of race, color or national origin 

in violation of the rights of plaintiffs and the class they rep- 

resent under Title VI and 42 U.S.C. § 1983; 

(d) enjoining Methodist Hospital of Gary to take affirm- 

ative action to overcome the effects of their present and past 

discriminatory actions, such affirmative action to include, inter 

i) ceasing all planned and future expansion of 

Broadway Methodist Hospital; 

ii) placing all new equipment and services in 

Gary Methodist Hospital; 

1ii) submission of a plan to the Court and HEW outlining 

Bn 

 



steps which shall be taken to assure the desegre- 

  

gation of the staff and patient populations at 

Gary Methodist Hospital and Broadway Methodist 

Hospital; 

iv) providing transportation to minority 

and handicapped patients, visitors and employees 

who are residents of Gary who desire to go to or 

to work at Broadway Methodist Hospital; 

(e) enjoining the Secretary from engaging in poli- 

cies and practices which deprive the plaintiff and the class 

she represents of rights secured by Title VI, including, but 

not limited to, orders: 

i) enjoining the Secretary from refusing or 

failing to ensure that recipients of federal finan- 

cial assistance, including Methodist Hospital of 

Gary, Inc., do not segregate or discriminate against 

persons on the basis of race, color or asbional 

origin; 

ii) enjoining the Secretary to enforce the site 

selection provisions of the Title VI regulations, 45 

C.F.R. § 80.3(b)3 with respect to all recipients of 

federal financial assistance, including Methodist 

Hospital of Gary, Inc.; 

iii) enjoining the Secretary from granting federal 

financial assistance to Methodist Hospital of Gary, 

Inc., in connection with loans and grants for Broadway 

Methodist Hospital as long as it segregates and dis- 

criminates against persons in the provision of services 

on the basis of race, color or national origin; 

Gs 

 



iv) enjoining the Secretary, in administering 

  

the Hill-Burton Act and its successor law, Title 

XVi of the Public Health Services Act, 42 U.5.C. § 3000 

et seq. § 314 and its successor law Title XV of the 

Public Health Services Act, 42 U.S.C. § 3000k, et seq., 

to assure that requirements of Title VI are met; 

v) enjoining the Secretary from granting and con- 

tinuing federal financial assistance to Methodist 

Hospital of Gary, Inc., in connection with loans and 

grants for Broadway Methodist Hospital until the 

actions listed in sub-paragraph 21 (d) above are met. 

(3)  asrdtng costs and reasonable attorneys' fees; 

(k) granting such additional relief as the court 

deems just and equitable. 

Respectfully submitted, 

LL Tn o> ol) tem 
/JJACK GREENBERG 

/ MELVYN R. LEVENTHAL 
BETH J. LIEF 

10 Columbus Circle 

New York, New York 10019 

  

JULIAN ALLEN 

2009 Broadway 

Gary, Indiana 46407 

MARILYN G. ROSE 

CHRISTINE B. HICKMAN 

1751 N Street, N. WwW. 

Washington, D. C. 20036 

Attorneys for Plaintiffs 

-10- 

 



  

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF INDIANA 

HAMMOND DIVISION Fl I L D 

JUN 1 0 1977 
  

BARBARA WESSON, et al., U. S. DISTRICT coum Vv, s. ICT 

Plaintiff, 

Vou 

Cause No. H 76-373 

METHODIST HOSPITAL OF 

GARY, INC., and JOSEPH 

CALIFANO, 

Defendants. i: 

  

STATE OF INDIANA) 

} 88.: 

COUNTY OF LAKE ) 

BARBARA WESSON, being duly sworn, deposes and says: 

l. I was originally a named plaintiff in the above-entitled 

action and am submitting this affidavit to explain my decision 

to drop my name as a plaintiff in this case. 

2. I am a black citizen of the United States and a long- 

time resident of Gary and have used the facilities of Gary 

Methodist Hospital. I believed that a suit should be insti- 

tuted against Methodist Hospital of Gary, ne, and the 

United States Secretary of Health, Education and Welfare, and 

desire to be a named plaintiff in such action for the following 

reasons: 

a) The construction and expansion of Broadway 

Methodist Hospital by Methodist Hospital of Gary, 

Inc., which was funded and approved by HEW has had 

and will continue to have the effect of injuring me 

 



  

and other minority residents of Gary, Indiana, by 

draining needed funds and personnel from Gary 

Methodist Hospital, a facility which is older than 

Broadway Methodist Hospital and which serves a 

larger population; 

(b) The placement of crucial x-ray equipment 

at Broadway Methodist Hospital rather than Gary 

Methodist Hospital discriminates against minority 

residents of Gary who require the use of such equip- 

ment but who, in many cases, cannot reach Broadway 

Methodist Hospital without severe difficulty because 

of the lack of public transportation from Gary to 

the suburban facility; 

(c) The proposed expansion of Broadway Methodist 

Hospital will exacerbate the conditions that already 

exist and the injury already suffered by minority resi- 

dents of Gary. 

3. I was able to learn many of the facts concerning the 

discrimination by Methodist Kos 5LthL of Gary, Inc., because of 

my affiliation with the Medical Center of Gary, Inc. Whatever 

goals I hold for the Medical Center of Gary, Inc., or what- 

ever differences the Medical Center might have or have had with 

the Methodist Hospital of Gary, Inc., have nothing whatsoever 

to do with the purposes of the instant action. However, de- 

fendants have continually referred to my affiliation with the 

Medical Center of Gary, Inc., and I believe that my continued 

presence as a named plaintiff in this action might confuse the 

true purposes of the lawsuit: to guarantee the right of myself 

ee 

 



  

and other minority residents to lack of discrimination and 

segregation in a health care facility financed by federal 

funds. Therefore, because I continue to support that purpose, 

I have decided to withdraw as a named plaintiff. 

Respectfully submitted, 

ad en 
  

BARBARA WESSON 

Sworn to before me this 

20 day or Yay” 
: 

1977. : 

  

  

Mv Conn ASS (po CX PVCs 

[rely 

 



  

IN THE UNITED STATES DISTRICT COURT [=| [° ED 

FOR THE NORTHERN DISTRICT OF INDIANA 

UN 1 01977 
HAMMOND DIVISION At 

FRANCIS T. GRANDYS ee M 
» CLERK U. S. DISTRICT COURT 

  

BERNICE TERRY, et al., 

Plaintiff, 

Ve : Cause No. H 76-373 

METHODIST HOSPITAL OF GARY, 

INC., and JOSEPH CALIFANO, 

Defendants. ; 

  

STATE OF INDIANA) 

} SS.: 

COUNTY OF LAKE ) 

ROSA KEETON, being duly sworn, deposes and says: 

l. I was originally a named plaintiff in the above 

entitled action and am submitting this affidavit to explain 

why I have decided to drop my name as a plaintiff in this 

case. 

2. I am a black citizen of the United States and a 

resident of Gary for approximately forty years. 

3. I originally desired to be a named plaintiff in 

an action against Methodist Hospital of Gary, Inc., and the 

United States Secretary of HAZLLH, Education and welfare for 

the following reasons: 

(a) I believe the construction and expan- 

sion of Broadway Methodist Hospital by Methodist 

Hospital of Gary, Inc., and funded and approved 

 



  

by HEW has had and will continue to have the 

effect of draining needed resources, personnel 

and funds from Gary Methodist Hospital, the 

facility which serves the minority residents of 

Gary; 

(b) I believe that the decision to con- 

struct and expand Broadway Methodist Hospital 

and to place crucial x-ray equipment there 

rather than to modernize Gary Methodist Hospital 

discriminates against the minority residents of 

Gary; : » 

(c) Minority residents of Gary, including 

myself, are injured by the discriminatory delivery 

of health care by Methodist Hospital of Gary, Inc. 

4. I continue to hold the beliefs which prompted me to 

join as a named plaintiff in this lawsuit. I did not join 

this action to promote the interests of the Medical Center of 

Gary, Inc., but only to enforce the rights guaranteed to me and 

others under the Constitution of the United States and federal 

law. However, defendants continually question me and refer to 

the fact that I am associated with the Medical Center of Gary, 

Inc. I believe that my continued presence as a named plaintiff 

might confuse the issues. I therefore have decided to withdraw 

as a named plaintiff in order that the true purpose of this 

lawsuit not be impeded. 

Respectfully submitted, 

[dt fol 
; ROSA KEETON 
  

Sworn to before me this 

BYE day oe May 
1977 

Hod ELLY. 

  

  

Me Coir nn sClonN EXPIRES 

/2¢/50 

 



  

* *® 

IN THE UNITED STATES DISTRICT COURT 

  

FOR THE NORTHERN DISTRICT OF INDIANA Fl LE D 
HAMMOND DIVISION UN 1 0 1077 

TUS igganDYS, Cle 
EDDIE GRAY, et al., 

Plaintiff, 

Ve 

Cause No. H 76-373 

METHODIST HOSPITAL OF GARY, 

INC., and JOSEPH CALIFANO, 

Defendants. : » 

  

STATE OF INDIANA) 
} SS. 

COUNTY OF LAKE ) 

EDDIE GRAY, being duly sworn,deposes and says: 

l. I was originally a named plaintiff in the above-entitled 

action and am submitting this affidavit to explain to the Court 

my decision to withdraw as a named plaintiff in this action. 

2. I am a black citizen of the United States and a resi- 

dent of Gary who is likely to require the use of health care 

facilities. | 

3. I originally desired to be a named plaintiff in an 

action against Methodist Hospital of Gary, Inc., and the United 

States Secretary of Health, Education and Welfare, because I 

believe the construction and expansion of Broadway Methodist 

Hospital by Methodist Hospital of Gary, Inc., which was funded 

and approved by HEW has had and will continue to have the effect 

of creating a segregated health care. system which discriminates 

against me and other minority residents of Gary. 

 



  
  

* ps * 

4. I continue to believe that the prosecution of the 

above-entitled action is necessary to secure the rights 

guaranteed to me and other minority residents of Gary under 

the Constitution of the United States and federal law. 

However, I also believe that my affiliation with members of 

the Board of the Medical Center of Gary, Inc., may lead to 

the misbelief that my participation as a named plaintiff in 

this lawsuit is not solely to seek relief from the discrimina- 

tion and segregation referred to above. I, therefore, have 

decided to withdraw as a named plaintiff in ‘order that the 

true purpose of this lawsuit and its prosecution not be con- 

fused in any way. 

Respectfully submitted, 

Lh Be pc po 
EDDIE a 
  

Sworn to before me this 

297 day of Mae ’ 
  

1977. 
/ 

LoL BAL, = ’ / 2 eo 7 V/4 

Ie ~~ (7 wa 9% / Aid 

  

  

24 

ir Leinrinis§ tons EA Cle cx 

9/ot fd 

  

 



   
       

  

Y HK. Ulvits cit 
U N A b= ~ 

  

          

  

  

  
  

jy. e | ; K I © OTHER NUMBER | DLM i Fag INUIR ESt 

¥55/2 76 373 2/2 2440 1.1% 5508 76 373 

PLAINTIFFS DEFENDANTS 

| WESSON, Barbara Leek; | METHODIST HOSPITAL OF GARY, | 
BERNICE TERRY; EDDIE GRAY; INC., and DAVID MATHEWS, Secre- 

ROSA KEETON tary of Department of Health, 
Education and Welfare 

CAUSE 

42 USCA 291-291-0; 42 USCA 200D 14th Amendment to Constitution of 
United States -- Violation by Defendant, Methodist, of Civil Rights 
Assurance Agreement dated July 27, 1973. 
  

ATTORNEYS 

Julian B. Allen 

2009 Broadway 
Gary, IN 46409 
219/886-3666 

Charles B. Miller, 
2009 Broadway 
Gary, IN 46407 

Esq. 

Jack Greenberg 
Beth Lief 
10 Columbus Circle 
New York, N.Y. 10019 
212-586-8397 

larilyn G. Rose 
Christine B. Hickman 
1751 N. Street, N. WN. 

Washington, D. C. 20030 

Milton R. Leventhal 

10 Columbus Circle 

New York, New York 10019 

FOR DEFT. METHODIST HOSPITAL: 
  

L— Bruce Sayers 
5525 Broadway 
Gary, IN 46410 
981-2557 

VY, 8S, Atty, 
  

Slit alten) ECA 
SEL Lr Dal be APPRAISE 

rt, rs tad 

- — p / i 9 : : Cy 

TCO DTI SC AHCALTIS A CE 
- 

Qi rod oo, Zh Gebod 

  

  

  
  

  

    
  

  

          

CHECK FILING FEES PAID STATISTICAL CARDS 

HERE DATE RECEIPT NUMBER C.D. NUMBER CARD DATE MAILED 
IF CASE WAS 
FILED IN JS5 

FORMA S-6 
PAUPERIS     
  UNITED STATES DISTRICT COURT DOCKET DC-111 (Rev. 1/7 

 



  

May 17, 1977 

Julian B, Allen, Esq. 
Chuck Miller, Esq. 

2009 Broadway 

Gary, Indiana 46410 

Res Terry v. Methodist Hospital of Gary, Inc. 
  

Dear Chuck: 

As I indicated to you on the phone, enclosed 
is the First Amended Complaint in our first 

case, as well as affidavits for Barbara Wesson, 

Bernice Terry and Eddie Gray to sign. As soon 
as possible, please have them sign the affidavits 
and file the complaint immediately so that we 

do not have to make a motion to amend the com- 

plaint. 

  

Looking forward to hearing from you about the 

construction at Broadway Methodist Hospital. 

Sincerely, 

Beth Lief 

BL/x 
Enclosures [||fd12659e-3758-45e0-ac86-e9b9862cf7e7||]