Anderson
v.
Los Angeles County
Dept. of Health Services

[a layperson's guide to the suit and the issue]

	Layperson's guide
I	Index
II	Introduction
III	Procedural elements
IV	Legal Basis for Claim
V	Petitioner's argument
VI	Prayer for Relief
	Writ
	Other

TEXT OF
OPENING BRIEF
AS FILED
CAL SUPERIOR COURT
LOS ANGELES
JULY 19, 2002
(PRINT)

VI. Prayer for Relief

A. Writ of mandate

1. Seek reimbursement

Wherefore, petitioner requests the court to issue a writ of mandate instructing respondent to seek reimbursement from those sponsoring immigrants for means-tested public benefits provided to those sponsored immigrants.

2. Collect necessary data

Wherefore, petitioner requests the court to issue a writ of mandate instructing respondent to take whatever reasonable steps necessary and collect whatever data necessary to create the conditions necessary in order to be in compliance with 8 U.S.C. 1183a (b)(1)(A).

3. Open to scrutiny

Wherefore, petitioner requests the court to issue a writ of mandate instructing respondent to make de-identified records available for public inspection within the guidelines of the Privacy Rule governing the disclosure of medical records.

B. Attorney's fees, costs, other relief deemed appropriate

Pursuant to California Code of Civil Procedure section 1021.5 (2003), petitioner requests reimbursement for all attorney's fees and costs associated with this action that is brought in the public's interest.

Petitioner requests any other relief that the court deems appropriate.

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