Motion to Supplement the Record; Notice of Motion

Public Court Documents
June 3, 1975

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Motion to Supplement the Record; Notice of Motion preview

4 pages

Includes Correspondence from Leventhal to Clerk.

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  • Case Files, Norwood v. Harrison - Hardbacks. Motion to Supplement the Record; Notice of Motion, 1975. 7edb72d0-722e-f111-88b4-7c1e526962fd. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/1f091cf3-71c9-4924-8e00-3b978dbf87dd/motion-to-supplement-the-record-notice-of-motion. Accessed July 18, 2026.

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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF MISSISSIPPI 

WESTERN DIVISION 

DELORES NORWOOD, et al., 

Plaintiffs, 

vs. LC No. WC 70-53-K 

D.L. HARRISON, eft al., 
ww 

Defendants. 

MOTION TO SUPPLEMENT THE RECORD 
  

Plaintiffs respectfully move the Court for leave to 

supplement the Record with the attached Revenue Ruling 75-231 

issued by the Internal Revenue Service, and would show in support 

thereof: - 

1. There is pending before the Court plaintiffs' motion 

for an award of attorneys' fees; the reasonableness of the award 

requested, is determined in part by the importance and impact of 

the case or "the results obtained." Johnson v. Georgia Highway 
  

Express, 488 v.24 714, 718 (5th Cir. 1974). 

2. The attached IRS release articulates a new policy 

relating to private schools operated by church or religious organ- 

izations which policy resulted in large measure from the litigation 

and decisions obtained in Norwood. (See page 4 of attachment). 

It is additional evidence that the fee award requested is respon- 

sive to the "results obtained." (See also Memorandum in Support 

of Counsel Fees, p.l1l0).   
 



  

The proposed supplement to the record is therefore 

- 

3. 

relevant to the issues raised by plaintiffs motion for an award of 

attorneys' fees, and accordingly should be considered by the Court. 

Respectfully submitted, 

    
JACK GREENBERG 
MEIlVYN R. LEVENTHAL 

10 Columbus Circle 

Suite 2030 

New York, New York 10019 

Attorneys For Plaintiffs. 

CERTIFICATE OF SERVICE 
  

I hereby certify that on this th day of June, 1975 1 

served one copy of the foregoing Motion to Supplement the Record 

upon counsel for defendants by mailing same to him at the address 

set forth below, via United States airmail, postage prepaid. 

Giles Bryant, Esq. 
Assistant Attorney General 
P.O. Box 220 
Jackson, Mississippi 39205 

dor] 1 
        

   



      

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF MISSISSIPPI 

WESTERN DIVISION 

DELORES NORWOOD, et al., « 

Plaintiffs, 

vs. : Es No. WC 70-53-K 

D.L. HARRISON, et al., 

Defendants. 

NOTICE OF MOTION 
  

PLEASE TAKE NOTICE that plaintiffs will bring on for 

hearing the attached Motion to Supplement the Record, on June 8, 

1975, beginning at 9 A.M., before the Honorable William C. Keady, 

United States District Judge, in the United States Courthouse, 

Greenville, Mississippi. 

Respectfully, 

  

ory 
  

hE R. LEVENTHAL [||b2cf48f8-f034-415e-ace9-679f80fbcdbd||]

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