[Memorandum: Motion for protection and in camera proceedings] Page: 1 of 8
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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
DALLAS GAY ALLIANCE, INC., et al.,
Plaintiffs,
VS. .:Civil Action No.:
DALLAS COUNTY HOSPITAL : CA 3-88-1394-H
DISTRICT, D/B/A PARKLAND
MEMORIAL HOSPITAL, et al.,
Defendants.
MEMORANDUM OF LAW IN OPPOSITION TO
DEFENDANT DALLAS COUNTY HOSPITAL DISTRICT'S
MOTION FOR PROTECTION AND
IN CAMERA PROCEEDINGS
Defendant DALLAS COUNTY HOSPITAL DISTRICT d/b/a Parkland Memorial
Hospital (hereafter "Parkland") has made a motion for a hearing in camera which is
unsupported either by reason or authority.
Parkland seeks to assert the common law informer privilege in order to present
secret testimony against plaintiffs and their counsel in an attempt to defeat plaintiffs'
motion for class certification with wholly irrelevant slander. Plaintiffs, of course, have
not seen the sealed submission but the allegation revealed in the public filing that
plaintiffs' counsel, M. William Nelson, has made improper threats against a potential
Parkland witness is absolutely untrue as a matter of fact, and malicious as a matter of
law. See Affidavit of M. William Nelson, attached hereto as Exhibit "A", submitted
herewith.
This court need not, however, even reach the substance of Parkland's allegations,
since Parkland is not entitled to assert the informer privilege in the first place.
Privilege, to protect the free flow of information to law enforcement agencies, is not
remotely at issue here.PLAINTIFFS' MEMORANDUM OF LAW - PAGE 1
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[Memorandum: Motion for protection and in camera proceedings], text, October 19, 1988; (https://texashistory.unt.edu/ark:/67531/metadc916414/m1/1/: accessed June 19, 2024), University of North Texas Libraries, The Portal to Texas History, https://texashistory.unt.edu.; crediting UNT Libraries Special Collections.