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New York County Clerk's Index No. 117882/99
New York Supreme Court
Appellate Division-First Department
BRAD H., et al.,

Plaintiffs-Respondents,

- against -

THE CITY OF NEW YORK, et al.,

Defendants-Appellants.


BRIEF FOR AMICI CURIAE:

The National Alliance for the Mentally Ill, NAMI-Metro-NYC, NAMI - New York State, The Judge David L. Bazelon Center for Mental Health Law, The American Orthopsychiatric Association, The Coalition for the Homeless, The Coalition of Voluntary Mental Health Agencies, Inc., Community Access, the Legal Aid Society of the city of New York, The Mental Health Association of New York State, Inc., The Mental Health Empowerment Project, The Mood Disorders Support Group, Inc., The New York Association of Psychiatric Rehabilitation Services, The New York State Defenders Association, The New York State Independent Living Council and The State Communities Aid Association

National Alliance for the
Mentally Ill
Colonial Place Three
2107 Wilson Boulevard
Suite 300
Arlington, Virginia 22201-3042
Gibson, Dunn & Crutcher LLP
200 Park Avenue
New York, New York
10166-0193
(212) 351-4000
Attorneys for Amici Curiae
The Judge David L. Bazelon
Center for Mental Health Law
1101 15th Street, NW, Suite 1212
Washington, D.C. 20005-5002

The National Alliance for the Mentally Ill ("NAMI"), NAMI-Metro-NYC, NAMI-New York State, The Judge David L. Bazelon Center for Mental Health Law, The American Orthopsychiatric Association, The Coalition for the Homeless, The Coalition of Voluntary Mental Health Agencies, Inc., Community Access, The Legal Aid Society of the City of New York, The Mental Health Association of New York State, Inc., The Mental Health Empowerment Project, The Mood Disorders Support Group, Inc., The New York Association of Psychiatric Rehabilitation Services, The New York State Defenders Association, The New York State Independent Living Council, and The State Communities Aid Association (collectively "amici") respectfully submit this brief in opposition to defendants' appeal of the Order of the Supreme Court, New York County (Braun, J.S.C.), dated July 9, 2000, and entered on July 18, 2000, which preliminarily enjoined the defendants from continuing to violate Section 29.15 of New York's Mental Hygiene Law and Part 587, Title 14 of New York's Code of Rules and Regulations ("NYCRR") by failing to provide discharge planning to mentally ill inmates of New York City jails ("City Jails") as part of the mental health treatment these inmates receive while incarcerated.


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