Defendant's Original Answer to Plaintiffs' Second Amended Complaint with Certificate of Service

Public Court Documents
October 9, 1992

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Defendant's Original Answer to Plaintiffs' Second Amended Complaint with Certificate of Service preview

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Impact area
- Economic Justice
Topic
- Healthcare
LDF Attorneys
- Bill Lann Lee
- Kirsten Levingston
Cooperating Attorneys
Organizations
Matter
- Thompson v. Raiford
Case
- Thompson v. Raiford
U.S. state
- California
Collection
- Case Files
Taxonomy
Identifier
- 03c13df2-5d40-f011-b4cb-0022482c18b0

Cite this item

Case Files, Thompson v. Raiford Hardbacks. Defendant's Original Answer to Plaintiffs' Second Amended Complaint with Certificate of Service, 1992. 03c13df2-5d40-f011-b4cb-0022482c18b0. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/942c647f-2276-444f-ba7c-85cff3ec1d04/defendants-original-answer-to-plaintiffs-second-amended-complaint-with-certificate-of-service. Accessed August 02, 2025.

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

LOIS THOMPSON ET AL.

Plaintiffs,
CIVIL ACTION NO.

V. 3-92-CV1539-R

BURTON F. RAIFORD
Defendant. un

DEFENDANT RAIFORD’S ORIGINAL ANSWER TO
PLAINTIFFS’ SECOND AMENDED COMPLAINT

TO THE HONORABLE JUDGE OF SAID COURT:

COMES NOW Defendant Burton F. Raiford, Commissioner of the Texas

Department of Human Services, and files this his Original Answer to Plaintiffs’ Second

Amended Complaint, showing the Court the following:

DEFENDANT'S ANSWER

1. Defendant Raiford denies the allegations in this paragraph which relate to the "state

defendant". He defers to the United States of America to answer all allegations pertaining

to the U.S.A.

2. Plaintiffs’ allege a basis for jurisdiction and as such the paragraph requires no response.

ORIGINAL ANSWER oie

Parties

3. Deny.

4. Admit.

5. Defendant Raiford defers to the United States of America to answer the allegations

contained in this paragraph.

CLASS ACTION ALLEGATIONS AGAINST RAIFORD

6. Defendant Raiford is without sufficient knowledge at this time to answer the allegations

contained in this paragraph.

7. Defendant Raiford is without sufficient knowledge at this time to answer the allegations

contained in this paragraph.

8. Deny.

9. Deny.

10. Defendant Raiford is without sufficient knowledge at this time to answer the allegations

contained in this paragraph.

11. Deny. contained in this paragraph.

CLASS ACTION ALLEGATIONS AGAINST THE USA

Defendant Raiford defers to the United states of America to answer the allegations

contained in paragraphs 12 - 17 in this section.

ORIGINAL ANSWER «D.

Facts - West Dallas

18. Defendant Raiford is without sufficient knowledge at this time to answer the allegations

contained in this paragraph.

19. Defendant Raiford is without sufficient knowledge at this time to answer the allegations

contained in this paragraph.

20. Defendant Raiford is without sufficient knowledge at this time to answer the allegations

contained in this paragraph.

21. Admit.

22. Defendant Raiford is without sufficient knowledge at this time to answer the allegations

contained in this paragraph.

23. Defendant Raiford is without sufficient knowledge at this time to answer the allegations

contained in this paragraph.

24. Defendant Raiford is without sufficient knowledge at this time to answer the allegations

contained in this paragraph.

25. Defendant Raiford is without sufficient knowledge at this time to answer the allegations

contained in this paragraph.

26. Defendant Raiford is without sufficient knowledge at this time to answer the allegations

contained in this paragraph.

State of Texas

27. Defendant Raiford is without sufficient knowledge at this time to answer the allegations

contained in this paragraph.

ORIGINAL ANSWER RY, .3.

28. Defendant Raiford is without sufficient knowledge at this time to answer the allegations

contained in this paragraph.

29. Defendant Raiford is without sufficient knowledge at this time to answer the allegations

contained in this paragraph.

United States

Defendant Raiford defers to the United States of America to answer the allegations

contained in paragraphs 31 and 32 of this section.

LOIS THOMPSON'S GRANDCHILDREN

36. Defendant Raiford is without sufficient knowledge to either admit or deny the

allegations contained in this paragraph.

Zachery Williams

37. Defendant Raiford is without sufficient knowledge to either admit or deny the

allegations contained in this paragraph.

38. Defendant Raiford is without sufficient knowledge to either admit or deny the

allegations contained in this paragraph.

39. Defendant Raiford is without sufficient knowledge to either admit or deny the

allegations contained in this paragraph.

ORIGINAL ANSWER

Calvin Thompson

40. Defendant Raiford is without sufficient knowledge

allegations contained in this paragraph.

41. Defendant Raiford is without sufficient knowledge

allegations contained in this paragraph.

Prentiss Mullins

42. Defendant Raiford is without sufficient knowledge

allegations contained in this paragraph.

43. Defendant Raiford is without sufficient knowledge

allegations contained in this paragraph.

44. Defendant Raiford is without sufficient knowledge

allegations contained in this paragraph.

Taylor Dixon

45. Defendant Raiford is without sufficient knowledge

allegations contained in this paragraph.

46. Defendant Raiford is without sufficient knowledge

allegations contained in this paragraph.

CLAIM AGAINST TDHS COMMISSIONER

47. Admit.

ORIGINAL ANSWER 83

either

admit

deny

the

48. Defendant Raiford is without sufficient knowledge to either admit or deny this

allegations contained in this paragraph.

49. Deny.

50. Defendant Raiford admits the allegations contained in this paragraph, however, the

EP test will be discontinued as a blood lead level test in November, 1992.

51. Deny.

52. Deny.

53. Admit.

54. Admit.

55. Admit.

56. Deny.

57. Deny.

58. Deny.

59. Deny.

CLAIM AGAINST USA

Defendant Raiford defers to the United States of America to address the allegations

contained in this section.

RELIEF SOUGHT AGAINST TDHS COMMISSIONER

Defendant Raiford denies that the Plaintiffs are entitled to any of the relief requested.

ORIGINAL ANSWER -6-

RELIEF SOUGHT AGAINST THE USA

Defendant Raiford defers to the United States of America to address this section.

Respectfully submitted,

DAN MORALES
Attorney General of Texas

WILL PRYOR
First Assistant Attorney

General

MARY F. KELLER
Deputy Attorney General for Litigation

JORGE VEGA, Chief
General Litigation Division

A
EDWIN N.\HORNE
Assistant Attorney General

Texas Bar No. 10008000

General Litigation Division
P.O. Box 12548 Capitol Station
Austin, Texas 78711-2548

(512) 440-4550 FAX (512) 447-0511

ORIGINAL ANSWER : ny 1

CERTIFICATE OF SERVICE

| certify that a true and correct copy of the foregoing document has been served via U.S.

Mail, certified, return receipt requested, on this the 7.8 day of October, 1992 to:

Michael M. Daniel
Laura B. Beshara
3301 Elm Street
Dallas, Texas 75226

ie
EDWIN N. HORNE
Assistant Attorney General

ORIGINAL ANSWER iS.

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Defendant's Original Answer to Plaintiffs' Second Amended Complaint with Certificate of Service

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