Declaration of Lois Thompson

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

DALLAS DIVISION 

  

  

    
THE UNITED STATES OF AMERICA, 

Defendants. 

LOIS THOMPSON on behalf of and * 
as next friend to TAYLOR * 
KEONDRA DIXON, ZACHERY X. * 

WILLIAMS, CALVIN A. THOMPSON * No. 3-92 CV 1539-R 
and PRENTISS LAVELL MULLINS, * 

Plaintiffs, * Civil Action 
* 

Vv. * Class Action 
x wn 

BURTON F. RAIFORD, in his * NORTHERN DISTRICT OF TEXAS 
capacity as Commissioner of * . | | rE 
the Texas Department of Human * LEU 
Services, * | 

* ¥ 

and % 
* 

* 

* 

* 

* 

DECLARATION OF LOIS THOMPSON 
  

I, Lois Thompson, am the grandmother of Zachery Williams, 

Calvin Thompson, Prentiss Mullins, and Taylor Dixon. The follow- 

ing facts that are also set out in Plaintiffs Second Amended 

Complaint are true and correct to the best of my knowledge: 

1. The four grandchildren are Zachery Williams (DOB 11-17- 

88), Calvin Thompson (DOB 8-22-89), Prentiss Mullins (DOB 11-24- 

90), and Taylor Dixon (DOB 12-14-91). The children’s homes are in 

the 1800 block of Angelina St. and within the boundaries of the 

EPA West Dallas emergency removal site. Ms. Thompson resides in 

the same block at 1826 Angelina. 

Zachery Williams 

2. Zachery Williams has been receiving EPSDT screening and 

Medicaid treatment at the Carver Children’s Clinic in West Dallas 

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since he was 2 months old. He was seen by the Clinic through the 

State Medicaid program on 1-31-89, 3-24-89, 5-9-89, 8-27-90, 11- 

19-90, and 11-11-91. At no time was Zachery given a blood lead 

test.! At the 8-27-90 visit he was given an EP test which showed 

a less than 35 ug/dl value. 

3. On 5-20-92 Zachary was tested by the blood lead test at 

the request of his attorneys. The result was 21 mcg/dl. No 

intervention was provided other than a re-test on 6-09-92. That 

retest sample was lost. On July 9, 1992 Ms. Thompson’s lawyers 

requested Zachery’s medical records from the Carver Clinic. The 

Clinic had Zachery back in for another blood sample on 7-14-92. 

This sample returned a blood lead level of 7 mcg/dl. Zachery’s 

records were finally released on 7-20-92. 

4. There is nothing in Zachery’s medical records to show 

that he has received any of the intervention for lead poisoning 

required by CDC. 

Calvin Thompson 

5. Calvin was seen by the Carver Children’s Clinic under the 

Medicaid program on 10-16-89, 12-15-89, 2-16-90, 6-19-90, 11-26- 

90, and 11-11-91. Only on the 11-11-91 was Calvin given an EP 

test for blood lead level. The test returned a value of less than 

35 ug/dl. On 5-18-92 Calvin, at the request of his attorneys, was 

given a blood lead test with a 19 mcg/dl result. He was retested 

on 6-03-92 with a 14 mcg/dl result. 

6. There is nothing in Calvin’s medical record show that he 

  

1 on 11-11-91 Zachery’s mother refused the EP test. 

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has received any of the intervention for lead poisoning required 

by CDC. 

Prentiss Mullins 

7. Prentiss was seen by the Carver Children’s Clinic under 

the Medicaid program on 1-17-91, 5-1-91, and 10-11-91. Prentiss 

was given no tests to determine blood lead levels. 

8. Prentiss was given blood lead level tests, at the request 

of his attorneys, on 5-18-92 and 6-03-92. The tests showed levels 

of 18 mcg/dl and 14 mcg/dl. 

9. There is nothing in Prentiss’ medical records to show 

that he received any of the intervention for lead poisoning 

required by CDC. 

Taylor Dixon 

10. Taylor was six months old on 6-14-92. She was given a 

blood lead level test at her grandmother’s request when she was 

less than 5 months old on 5-05-92. The blood lead level test 

showed 9 mcg/dl. Taylor has started her life with a blood lead 

level high enough to be associated with impaired learning. 

11. There is nothing in Taylor’s medical records to show 

that she has received any of the intervention for lead poisoning 

required by CDC. 

 



“ % 

  

I, Lois Thompson, declare under penalty of perjury that the 

above facts relating to my grandchildren are true and correct to 

the best of my knowledge. 

Kone 
  of "Lois Thompson / 

Respectfully submitted, 

MICHAEL M. DANIEL, P.C. 

3301 Elm Street 

Dallas, Texas 75226-1637 
(214) 939-9230 

By: Lg ANY, 
Michael M. Daniel 
State Bar No. 05360500 

  

By: ~OUNA RB. ALOR 0 
~TLaura B. Beshara 
State Bar No. 02261750 

  

ATTORNEYS FOR PLAINTIFFS