Declaration of Lisa Matthews

    JOEL R. Tm | 4 

JACQUELINE WARREN DEC 2 6 1990 

2 || NATURAL RESOURCES DEFENSE COUNCIL 

617 S. Olive Street, Suite 1210 

3 | Los Angeles, CA 90014 

  

(213) 892-1500 Ener eT ORIGINAL 
. FLL E D 

JANE PERKINS 
5 | NATIONAL HEALTH LAW PROGRAM DEC 2 

2639 S. La Cienega Blvd. 0 1990 

6 | Los Angeles, CA 90034 RICHA 
(213) 204-6010 No ERK, US. DATaEKI 

2 RICT OF CALIF 
STEPHEN RONFELDT CALIFORNIA 

gs | SUSAN SPELLETICH 
LEGAL AID SOCIETY OF ALAMEDA COUNTY 

9| 1440 Broadway, Suite 700 

Oakland, CA 94612 

10] (415) 451-9261 

11 {| BILL LANN LEE 
KEVIN S. REED 

12 | NAACP LEGAL DEFENSE AND EDUCATIONAL FUND, INC. 

315 W. 9th Street, Suite 208 

13 || Los Angeles, CA 90015 

(213) 624-2405 El wo 

MARK D. ROSENBAUM G 90 38 20 SFL 

15 | ACLU FOUNDATION OF SO ERN LIFORNIA™ 

633 South Shatto Place 

16 || Los Angeles, CA 90005 

(213) 480-3221 

  
  

17 
Attorneys for Plaintiffs 

18 (Additional counsel on following page) 

19 UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF CALIFORNIA 

20 
ERIKA MATTHEWS AND JALISA MATTHEWS, ) 

21 | by their guardian ad litem Lisa ) Civ. No. 

Matthews, and PEOPLE UNITED FOR A ) 

22 || BETTER OAKLAND, On Behalf of ) CLASS ACTION 

Themselves and All Others Similarly ) 

23 | Situated, ) DECLARATION OF LISA 
) MATTHEWS 

24 Plaintiffs, ) 

) 

25 | Vv. ) 

) 
26 || KENNETH KIZER, Director, California ) 

Department of Health Services, ) 

27 ) 
Defendant. ) 

28 ) 
        DECLARATION OF LISA MATTHEWS 

 



1 @ bi 

2 | EDWARD M. CHEN 

ACLU FOUNDATION OF NORTHERN CALIFORNIA 

3] 1663 Mission Street, Suite 460 

San Francisco, CA 94103 

4| (415) 621-2493 

  

  

5 || Attorneys for Plaintiffs 

27 

28       DECLARATION OF LISA MATTHEWS 

 



  

27 

28     

J 4 
DECIARATION OF LISA MATTHEWS 
  

I, LISA MATTHEWS, declare as follows: 

1. I am the mother of plaintiffs Erika Matthews and Jalisa 

Matthews. We reside at 931 Dawson, Apt. 5, Long Beach, California 

90804, which is located in the County of Los Angeles, State of 

California. 

2. Erika is two years old. Jalisa is one year old. 

3. Both have causes of action against the above-captioned 

defendant on which they wish to bring suit in this court. Causes 

of action arise out of the fact that a) my children are in need of 

lead blood testing and, perhaps, treatment; b) they are eligible 

to receive such testing and treatment from the State of California 

Medi-Cal program; and c) they have not received such testing and 

treatment because of the defendant's failure to establish and 

implement a lead screening and treatment program. 

4. My children Erika and Jalisa do not have any other 

guardian or duly appointed representative. 

5. I am fully competent to protect the rights of my 

children Erika and Jalisa as plaintiffs in the above-entitled 

action if I am appointed as their guardian ad litem for that 

purpose. 

6. Y have no interest adverse to my children Erika and 

Jalisa, and I am not associated in business with any of the 

adverse parties or their counsel in the above-entitled action. 

7. Subject to the approval of the court I have retained the 

counsel for plaintiffs in the above-entitled action to represent 

my children Erika and Jalisa in this action. The agreement with 

plaintiffs' counsel does not obligate my children Erika and Jalisa 

DECLARATION OF LISA MATTHEWS 

  

 



  

27 

28     
  

to pay any 8. fee to plaintiffs’ | except that an 

award, if any, of attorney fees in this case shall be directly 

payable by defendant to plaintiffs' counsel. 

I declare under penalty of perjury that the foregoing is 

true and correct. 

Executed on December / , 1990 at Long Beach, California. 

  

  
ZL Lr 

1Ti%a Mathéws, Mother of 

Erika and Jalisa Mathews 

  
DECLARATION OF LISA MATTHEWS