Memorandum in Support of Plaintiffs' Cross Motion for Summary Judgment and in Opposition to Defendants' Motion for Summary Judgment

Public Court Documents
August 22, 1996

Memorandum in Support of Plaintiffs' Cross Motion for Summary Judgment and in Opposition to Defendants' Motion for Summary Judgment preview

29 pages

Cite this item

  • Case Files, Campaign to Save our Public Hospitals v. Giuliani Hardbacks. Filing Notice for Brief Amicus Curiae PRIDE et al., 1998. 0b5ede50-6835-f011-8c4e-002248226c06. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/728157c8-0ed0-4adf-83a6-7b07263e4e3b/filing-notice-for-brief-amicus-curiae-pride-et-al. Accessed June 07, 2025.

    Copied!

    NEW YORK LAWYERS FOR THE 

PUBLIC INTEREST nc 

  

  

30 West 21st Street, 9th Floor, New York, NY 10010-6905 (212) 727-2270 

: Fax (212) 727-2996 
OGDEN N. LEWIS 

Davis Polk & Wardwell TDD: 212) 727-2997 

Chair 

ROBERT I. KLEINBERG 

CIBC Oppenheimer Corp. 

Vice Chair for Member Recruitment 

& Development 
November 12, 1998 

MITCHELL A. LOWENTHAL 

Cleary, Gottlieb, Steen & Hamilton 

Vice Chair for Member Recruitment BY FEDERAL EXPRESS 

& Development 
  

PATRICIA A. MARTONE Office of the Clerk 

Fish & Neave 

Vice Chair for Board Development Court of Appeals 

GERALD A. RO 20 Eagle Street 

Rosenman & aC Albany, NY 12207-1095 

Vice Chair for Member Relations 

JOHN H. HALL Re: Campaign to Save Public Hospitals v. Giuliani 
Debevoise & Plimpton 

Vice Chair for Litigation & Program Index No. 97-01339 (Queens County) 

MARIA IMPERIAL 
Victim Services 
Secretary To Whom It May Concern: 

TIMOTHY G. ROGERS ; ; ) ; 
Cadwalader, Wickersham & Taft Enclosed for filing please find a notice of motion for leave to file a brief as 

Treasiner amici curiae and my supporting affirmation, all bound as one document. I 

have also enclosed twenty (20) separately bound copies of the brief as 

amicus curiae in support of Plaintiffs-Respondents-Cross-Appellants and 

proof of personal service of the motion, affirmation and brief. 

  

JOAN VERMEULEN 

Executive Director 

EDWARD COPELAND 

General Counsel 

Thank you very much. 
MICHAEL A. ROTHENBERG 
Associate Director 

JOHN A. GRESHAM 
Senior Litigation Counsel 

Cordially, 

mere 

   
   

RUTH DEALE LOWENKRON | bh Ly 

Director, Disability Law Comer ly rele 

LOURDES I. REYES  Lotirdes 1 I Reyes 

KIMBERLY B. SWEET 

PAULINE H. YOO 

Staff Attorneys 

EDDIE BAUTISTA 

Community Liaison 

WENDY M. BRENNAN 

Director, Private Bar 

Involvement Programs 

 



  

COURT OF APPEALS 
STATE OF NEW YORK 

  

    

CAMPAIGN TO SAVE OUR PUBLIC HOSPITALS - QUEENS 
COALITION, an unincorporated association, by its 

member WILLIAM MALLOY, CAMPAIGN TO SAVE OUR PUBLIC 
HOSPITALS - CONEY ISLAND HOSPITAL COALITION, an 

unincorporated association, by its member PHILIP R. 
METLING, ANNE YELLIN, and MARILYN MOSSOP, 

Plaintiffs-Respondents-Cross-Appellants, 

-against- 

RUDOLPH W. GIULIANI, THE MAYOR OF THE CITY OF 
NEW YORK, NEW YORK CITY HEALTH AND HOSPITALS 

CORPORATION, and NEW YORK CITY ECONOMIC 
DEVELOPMENT CORPORATION, 

Defendants-Appellants-Cross-Respondents. 

  

BRIEF OF AMICUS CURIAE PROGRESSIVE RAINBOW INDEPENDENTS 
FOR DEVELOPING EMPOWERMENT (PRIDE), THE SHOREFRONT PEACE 
COMMITTEE, RICHARD N. GOTTFRIED, THE COUNCIL OF MUNICIPAL 

HOSPITAL COMMUNITY ADVISORY BOARDS, THE COMMISSION ON THE 
PUBLIC'S HEALTH SYTEM, IN SUPPORT OF PLAINTIFFS-RESPONDENT CROSS-   
  

  

APPELLANTS 

ARNOLD S. COHEN LOURDES I. REYES 
ARTHUR A. BAER NEW YORK LAWYERS FOR THE 
ALLISON BUSCH PUBLIC INTEREST 
QUEENS LEGAL SERVICES CORPORATION 30 West 21st Street, 9th Floor 
42-15 Crescent Street, 9th Floor New York, New York 10010 
Long Island City, New York 11101 (212) 727-2270 
(718) 392-5646 

RAYMOND BRESCIA 
URBAN JUSTICE CENTER 
666 Broadway, 10th Floor 

New York, New York 10012 
(212)533-0540 

  

  

REPRODUCED ON RECYCLED PAPER

Copyright notice

© NAACP Legal Defense and Educational Fund, Inc.

This collection and the tools to navigate it (the “Collection”) are available to the public for general educational and research purposes, as well as to preserve and contextualize the history of the content and materials it contains (the “Materials”). Like other archival collections, such as those found in libraries, LDF owns the physical source Materials that have been digitized for the Collection; however, LDF does not own the underlying copyright or other rights in all items and there are limits on how you can use the Materials. By accessing and using the Material, you acknowledge your agreement to the Terms. If you do not agree, please do not use the Materials.


Additional info

To the extent that LDF includes information about the Materials’ origins or ownership or provides summaries or transcripts of original source Materials, LDF does not warrant or guarantee the accuracy of such information, transcripts or summaries, and shall not be responsible for any inaccuracies.

Return to top