Motion to Require Court Panel to Proceed with Studies and Planning and Set a Schedule

    UNITED STATED DISTRICT COURT 
EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION

)
RONALD BRADLEY et al., )

)
Plaintiffs, )

)
v.  )

)
WILLIAM G. MILLIKEN, )

)
Defendants, )

)
and )

)
DENISE MAGDOWSKI, )

)
Defendants- )
Intervenors, )

)
and )

)
ALLEN PARK, et al., )

)
Defendants- )
Intervenors, )

)
and )

)
KERRY GREEN, et al., )

)
Defendants- )
Intervenors, )

)
and )

)
WAYNE COUNTY INTERMEDIATE )
SCHOOL DISTRICT, et al., )

Added Defendants. )
)

MOTION TO REQUIRE THE COURT-APPOINTED 
PANEL TO PROCEED WITH ITS STUDIES AND PLANNING AND TO SET 

A SCHEDULE FOR PROCEEDING IN THIS CAUSE

NOW COME Plaintiffs, Ronald Bradley, et al., and move 

this Honorable Court to require the desegregation panel 
previously appointed by this Court to proceed with its studies 
and planning to the end that there will be no unnecessary 
delay in the implementation of an effective plan of desegregation 

-as contemplated by the Opinion and Order of the United States 
Court of Appeals for the Sixth Circuit. Bradley v. Milliken,

F .2d (Nos. 72-1809 “ 72-1814, June 12, 1973 en banc)
Slip Op. 69-8 0. Plaintiffs further move that this Honorable



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Court order the defendants, including additional parties joined 

pursuant to Rules 19 and 21, to supply administrative and staff 

assistance to trie panel upon its request and that the reasonable 

costs incurred by the panel be paid as provided by the District 

Court’s Order of June 14, 1972. See Ibid. at 69, affirming 
in pertinent part, Order for Development of Plan of Desegregation 

(June 14, 1972) Part I.C. Plaintiffs further move that this 
Honorable Court issue an Order (a) providing a reasonable 
opportunity for the parties to file responses (or additional 

responses) to the reports submitted by the panel and the 
State Superintendent pursuant to the Court’s Order of June 14,

1972; (b) requiring that the panel submit its plan, and supporting 
studies, within 75 days from the entry of this Court’s Order;

(c) requiring that the parties file complete legal and 
practical objections and any alternatives to such plan, 
supporting briefs, and memoranda detailing,in full, proof to 

be offered at any hearing no later than 25 days after the 
filing of the panel’s report; (d) requiring that the parties 
reply within 25 days to such objections and alternatives as 
may be submitted; (e) and setting hearings on all relevant 

issues raised to commence 15 days thereafter following a 
pre-trial conference to sharpen the issues and consider the admiss­

ibility of evidence.

Respectfully submitted

LOUIS R. LUCAS 
WILLIAM E. CALDWELL

PAUL R. DIMOND

Ratner, Sugermon & Lucas 
525 Commerce Title Bldg. 
Memphis, Tennessee

906 Rose Avenue
Ann Arbor, Michigan 48104

J. HAROLD FLANNERY

NATHANIEL JONES 
General Counsel 
N . A . A . C . P.
1790 Broadway 
New York, New York

ROBERT PRESSMAN
Center for Lav; & Education 
6l Kirkland St.
Cambridge, Mass. 02138

E. WINTHER McCROOM 
3425 Woodburn Ave 
Cincinnati, Ohio

JACK GREENBERG
NORMAN J. CHACHKIN 

10 Columbus Circle 
New York, New York

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