Plaintiffs' Request for Production of Documents from Defendants

    Joel R. Reynold 

Jacqueline WarrWe 

NATURAL RESOURCES DEFENSE COUNCIL 

617 S. Olive Street, Suite 1210 

Los Angeles, CA 90014 

(213) 892-1500 

Jane Perkins 

NATIONAL HEALTH LAW PROGRAM 

2639 S. La Cienega Blvd. 

Los Angeles, CA 90034 

(213) 204-6010 

  
Stephen Ronfeldt 

Susan Spelletich 

LEGAL AID SOCIETY OF ALAMEDA COUNTY 

1440 Broadway, Suite 700 

Oakland, CA 94612 

(415) 451-9261 

BILL LANN LEE 

KEVIN S. REED 

NAACP LEGAL DEFENSE AND EDUCATIONAL FUND, INC. 

315 W. 9th Street, Suite 208 

Los Angeles, CA 90015 

(213) 624-2405 

MARK D. ROSENBAUM 

ACLU FOUNDATION OF SOUTHERN CALIFORNIA 

633 South Shatto Place 

Los Angeles, CA 90005 
(213) 487-1720 

Attorneys for Plaintiffs 

(Additional counsel on following page) 

  
UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

ERIKA MATTHEWS; et al., civ. No. C-90-3620 EFL 

CLASS ACTION 
  

) 
) 

) 
Plaintiff, ) PLAINTIFFS’ REQUEST 

) FOR PRODUCTION OF 
) DOCUMENTS FROM 

vs. ) DEFENDANTS 
) 
) 
) 
) 
) 

KENNETH KIZER, [SET ONE] 

Defendant. 

       



  

  

  

Edward M. Chen % 

ACLU FOUNDATION ¥F NORTHERN CALIFORNIA 

1663 Mission Street, Suite 460 

San Francisco, CA 94103 

(415) 621~2433 

  

 



  

  

  

Pursuant ‘@ 34 of the Federal Rulgs of Civil 

Procedure and Local Rule 230-2, plaintiffs hereby request that 

no later than March 11, 1991, defendant produce for inspection 

and copying all documents specified herein in defendants’ 

custody, possession or control at the offices of the National 

Health Law Program; 2639 S. LaCienega Blvd., Los Angeles, CA 

90034. 

DEFINITIONS 

A. The term "document" shall consist of all "documents" 

within the meaning of Fed. R. Civ. P. 34 and all "writings and 

recordings" within the meaning of Fed. R. Evid. 1001. 

B. The phrase "refer or relate", when used with respect 

to any given subject, means to consist, constitute, contain, 

concern, comprise, embody, reflect, identify, state, refer to, 

relate to, pertain to, deal with, or to have any logical or 

factual connection whatsoever with the subject. 

C. The term "Department" means the Department of Health 

Services, its agents, officers, employees, and any persons 

acting in concert therewith, including the Early Periodic 

Screening, Diagnosis and Treatment ("EPSDT") and Child Health 

and Disability Prevention ("CHDP") Programs. 

D. The term "State" means the State of California. 

INSTRUCTIONS 

A. Unless otherwise indicated, each demand for 

production requires the production of documents relating to 

the California Medical Assistance Program, also known as 

y Medi-Cal » " 

  

 



  

  

  

B. For document covered by the gallowing requests 

that is WE, production because Ld claim of 

privilege, identify each such document by date, author, 

recipient (s), subject matter, and basis for the claim of 

privilege. 

REQUESTS 

1. All documents that refer or relate to the 

Department’s policies and/or procedures, including such 

policies and/or procedures, regarding the EPSDT/CHDP Programs 

coverage of lead blood level assessments. 

2. All manuals, letters, operating instruction letters, 

bulletins or other documents promulgated after January 1, 1985 

that refer or relate to instructions to providers or lead 

blood. 

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assessment On nf co obtain reimbursement K. 1 providing such 

services. 

Dated: February 8, 1991 

  

NATURAL RESOURCES DEFENSE COUNCIL 

NATIONAL HEALTH LAW PROGRAM 

LEGAL AID SOCIETY OF ALAMEDA COUNTY 

NAACP LEGAL DEFENSE AND EDUCATIONAL 

FUND, INC. 

ACLU FOUNDATION OF SOUTHERN 

CALIFORNIA 

ACLU FOUNDATION OF NORTHERN 

CALIFORNIA 

   



          

  

  
    # CERTIFICATE OF SERVICrey 

1, Valerie zachary, declare: 

I am over the age of 18 years and not a party to the 

within action. My business address is 2639 S. La Cienega 

Blvd., Los Angeles, CA 90034. 

On February 8, 1991, I served the within PLAINTIFFS’ 

REQUEST FOR PRODUCTION OF DOCUMENTS FROM DEFENDANTS on 

defendants by depositing same in the U.S. Mails at Los 

Angeles, california, in a sealed, postage-paid envelope, 

addressed as follows: 

Harlan E. Van Wye 

Deputy Attorney General 

State of California 

Department of Justice 

2101 Webster Street 

Oakland, CA 94612-3049 

Linda Jane Slaughter 

state of California 

Department of Health Services 

Office of Legal Services 

714 P Street, Room 1216 

Sacramento, CA 95814 

Executed this th day of February, 1991 at LoS 

Angeles, California. 

I declare under penalty of perjury that the foregoing 

is true and correct. 

  a ]