Motion to Intervene as Defendants

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IN THE 

UNITED STATES COURT OF APPEALS 

FOR THE FIFTH CIRCUIT 

UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF MISSISSIPPI 

UNITED STATES OF AMERICA, 

Plaintiff- Appellant 

Court of Appeals 

Nos. 28030 and 

28042 

LAWRENCE COUNTY SCHOOL 

DISTRICT, ef al., Defendants-Appellees 

D.C. Civil Action 

No. 2216 

MOTION TO 

INTERVENE AS DEFENDANTS 
  

COME NOW O. R. Cross, Hunter Butler, James Ray 

Calhoun, Dr. John W. Waller, Pat Shivers and Eugene Myers, 

together with those other persons whose signatures appear on 

Exhibit 1, which is attached to this motion and made a part hereof 

for all purposes, who are parents, guardians and patrons of children 

enrolled in Grades 9 through 12 of Lawrence County School District 

and who file this motion to intervene in their own right and on their 

own behalf and on behalf of their respective children and wards, and 

on behalf of all others similarly situated, and respectfully move the 

Court for leave to intervene as defendants in this action in order to 

assert the defenses set forth in their proposed response, a copy of 

which is attached hereto and filed herewith, to the motion for supple- 

mental relief filed herein on or about January 7, 1970, by the NAACP 

Legal and Educational Defense Fund, Inc. for the following grounds 

and reasons: 

1. Applicants are parents, guardians and patrons, 

respectively of children, both White and Negro, enrolled in Grades 9 

through 12 of Lawrence County School District, which said children are 

presently attending one of the following schools of the District: Monticello 

 



  

High School, New Hebron High School, Topeka- Tilton High School, and 

McCullough Attendance Center. The purpose of this intervention is to 

seek the maintenance and preservation of said schools as they are pre- 

sently constituted and as they are presently being operated under orders 

of this Court and to oppose the motion for supplemental relief filed 

herein on or about Tanusey 7, 1970, by the NAACP Legal and Educational 

Fund, Inc. by which motion for supplemental relief said Fund is 

attempting to obtain an order of this Court requiring that all students 

of the Lawrence County School District in Grades 9 through 12 be forced 

to attend McCullough High School and other changes incidental thereto. 

2. Appliants file this motion for leave to intervene as 

defendants in their own right and on their own behalf and on behalf of 

their respective children and wards and on behalf of all others similarly 

situated who likewise oppose said efforts of said Fund, as reflected by 

the motion for supplemental relief. The class of persons similarly 

situated is so numerous that joinder of all members is impractical, 

there are questions of law or fact common to the class, the claims and 

defenses asserted and to be asserted by applicants as representative 

parties are typical of the claims and defenses of the class, the representa- 

tive parties will fairly and adequately protect the interests of the class 

and the relief sought by said motion for supplemental relief will adversely 

effect the constitutional rights of all members of the class. 

3. The applicants, and their respective children and wards, 

and those whom they represent, have valuable constitutional rights which 

are threatened by the action of said NAACP Legal and Educational Defense 

Fund, Inc. The children have a right to the best public education 

possible and the right to attend schools in their respective areas of 

residence without discrimination on account of race, and the right to 

education by duly elected officials without interference. The granting of 

the relief sought by said supplemental motion will violate the constitutional 

 



  

rights of said children and these applicants and those they represent 

under the equal protection and due process provisions of the United 

States Constitution and related provisions of the Mississippi Constitution. 

The hearing of said motion for supplementary relief, which seeks relief 

vitally affecting these applicants and their children and others similarly 

situated and which will amount to a violation of their constitutional rights, 

without an opportunity to be heard with respect thereto of itself would 

constitute a violation of their rights and the taking of their liberty 

and property without due process of law. 

4. Other reasons set forth in the response to said motion 

of for supplemental relief attached hereto and filed herewith. 

5. Supporting affidavit is annexed hereto as an exhibit 

and made a part hereof for all purposes. 

  re Fh ME oo Melle)” 
R. W. Heidelberg / 
Post Cffice Box 1070 

Hattiesburg, Mississippi 

Of Counsel for Applicants 

J. P. Patterson 

Post Office Box 11 

Monticello, Mississippi 

Francis Vining 

Monticello, Mississippi 

R. W. Heidelberg 

Heidelberg, Sutherland & McKenzie 

Post Office Box 1070 

Hattiesburg, Mississippl 39401 

Attorneys for Applicants (Intervener-Defendants) 

NOTICE OF MOTION 
  

Notice is hereby given that the foregoing motion for leave 

to intervene as defendants will be called up for hearing before the 

Honorable Dan M. Russell, Jr., United States District Judge, at the 

United States Courthouse in the City of Hattiesburg, Mississippi, at 

 



  

9:00 a. m., April 20, 1970, or as soon thereafter as counsel can be 

heard. 

WITNESS my signature on this /& A day of April, A. D., 

1970. 

EH Lo or 
Attorney for Applicants (Ylervener- 

Defendants) 

  

CERTIFICATE OF SERVICE 
  

I, the undersigned attorney for Applicants (Intervener- 

Defendants), do hereby certify that I have, this date, served the fore- 

going motion and notice, together with supporting affidavit and attached 

reply to motion for supplemental relief, by mailing a true copy of each 

by United States mail, properly addressed and postage prepaid to 

each of the following counsel of record: 

Honorable David L.. Norman Honorable Robert Hauberg 

Assistant Attorney General United States Attorney 

Department of Justice Federal Building 

Washington, D. C. Jackson, Mississippi 

Honorable Melvyn R. Leventhal Honorable Jack Greenberg 

Honorable Reuben V. Anderson Honorable Norman Chachkin 

Honorable Fred L. Banks, Jr. Honorable Jonathan Shapiro 

Honorable John A. Nichols Suite 2030 

538 1/2 North Farish Street 10 Columbus Circle 

Jackson, Mississippi 390202 New York, New York 10019 

Attorneys for NAACP Legal Attorneys for NAACP Legal 

and Educational Defense and Educational Defense 

Fund,. Inc. Fund, Inc. 

Honorable James S. George Honorable Robert G. Turnage 

Post Office Box 493 Monticello, Mississippi 

Monticello, Mississippi Attorney for Lawrence County 

Attorney for Lawrence County School District 

School District 

Honorable M. M. Roberts 

Fifth Floor, Citizens Bank Building 

Hattiesburg, Mississippi 

Attorney for Lawrence County School District 

WITNESS my signature on this 64 day of April, A. D., 
  

1970. 

er 1 LY a 
  

R. W. Heidelbergy/ 

 



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United States of America vs. Lawrence County School District 

Civil Action No, 2216 (D.C.): No, 28030 and 28042 (C,C. A, 5th) 
  

Signatures of parents, guardians and patrons of children enrolled 

in grades 9 - 12 of Lawrence County School District joining in 

motion for intervention, seeking to maintain and preserve Monticello 

High School, New Hebron High School, Topeka- Tilton High School, 

and McCullough Attendance Center, as these schools are presently 

constituted and as presently operated under court order. 

  
  

    

  
  

    

    

    

    

    

    

    

    

     
  

    

    

    

    

    

    

    

    

    

    

    

    

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United States of America vs. Lawrence County School District 

Civil Action No, 2216 (D.C.); No. 28030 and 28042 (C.C. A, 5th) 
  

Signatures of parents, guardians and patrons of children enrolled 

in grades 9 - 12 of Lawrence County School District joining in 

motion for intervention, seeking to maintain and preserve Monticello 

High School, New Hebron High School, Topeka- Tilton High School, 

and McCullough Attendance Center, as these schools are presently 

constituted and as presently operated under court order. 

  

Signature Address 
  

    

    

    

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Civil Action No. 2216 (D.C. ); No. 28030 and 28042 (C.C. A. 5th) 
  

Signatures of parents, guardians and patrons of children enrolled 

in grades 9 - 12 of Lawrence County School District joining in 
motion for intervention, seeking to maintain and preserve Monticello 
High School, New Hebron High School, Topeka- Tilton High School, 
and McCullough Attendance Center, as these schools are presently 

constituted and as presently operated under court order. 

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Civil Action No. 2216 (D.C. ); No. 28030 and 28042 (C. C. A. 5th) 
  

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in grades 9 - 12 of Lawrence County School District joining in 
motion for intervention, seeking to maintain and preserve Monticello 
High School, New Hebron High School, Topeka- Tilton High School, 
and McCullough Attendance Center, as these schools are presently 
constituted and as presently operated under court order. 

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Civil Action No, 2216 (D.C. );: No. 28030 and 28042 (C.,C. A, 5th) 
  

Signatures of parents, guardians and patrons of children enrolled 

in grades 9 - 12 of Lawrence County School District joining in 

motion for intervention, seeking to maintain and preserve Monticello 

High School, New Hebron High School, Topeka- Tilton High School, 

and McCullough Attendance Center, as these schools are presently 

constituted and as presently operated under court order. 

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United States of America vs. Lawrence County School District 

Civil Action No. 2216 (D.C.); No. 28030 and 28042 (C.C. A. 5th) 

Signatures of parents, guardians and patrons of children enrolled 
in grades 9 - 3a of Lawrence County School District joining in 
motion for intervention, seeking to maintain and preserve Monticello 
High School, Ne >w Hebron High School, Topeka- Tilton High School, 
and McCullough Attendance Center, as these schools are presently 
constituted and as presently operated under court order. \ 

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United States of America vs. Lawrence County School District 
Civil Action No’ 2216 (D.C.); No. 28030 and 28042 (C. C. A. 5th) 
    

Signatures of parents, guardians and patrons of children enrolled ' 
in grades 9 - 12 of Lawrence County School District joining in 
motion for intervention, seeking to maintain and preserve Monticello 
High School, New Hebron High School, Topeka- Tilton High School, 
and McCullough Attendance Center, as these schools are presently 

constituted and as presently operated under court order. 

  

  
    

  
  

    

  
  

Signature Address 

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United States of America vs. Lawrence County School District 
Civil Action No. 2216 (D.C.); No. 28030 and 28042 (C. C. A. 5th) 
  

Signatures of parents, guardians and patrons of‘children enrolled 

in grades 9 - 12 of Lawrence County School District joining in 

motion for intervention, seeking to maintain and preserve Monticello 

High School, New Hebron High  Sehoel, Topeka- Tilton High School, 

and McCullough Attendance Center, as these schools are presently 

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nited States of America vs. Lawrence County School District 

ction No, 2216 (D.C.): No. 28030 and 28042 (C.C. A, 5th) 
  

Signatures of parents, guardians and patrons of children enrolled 

es 9 - 12 of Lawrence County School District joining in 

motion for intervention, seeking to maintain and preserve Monticello 

  

  

    

  

      

      

    

High School, New Hebron High School, Topeka- Tilton High School, 

and McCullough Attendance Center, as these schools are presently 

constituted and as presently operated under court order. 

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United States of America vs. Lawrence County School District v 

Civil Action No. 2216 (D.C.); No. 28030 and 28042 (C. C. A. 5th) 
  

Signatures of parents, guardians and patrons of children enrolled 

Lawrence County School District joining in 
motion for intervention, 

in grades 9 -'12 of 

High School, New Hebron High School, Topeka- Tilton High School, 

and McCullough Attendance Center, as these schools are presently 
constituted and as presently operated under court order. 

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United States of America vs. Lawrence County School District 

Civil Action No, 2216 {(D.C.); No. 28030 and 28042 {C.C.A. 5th) 
  

Signatures of parents, guardians and patrons of children enrolled 

grades 9 - 12 of Lawrence County School District joining in 

motion for intervention, seeking to maintain and preserve Monticello 

High School, New Hebron High School, Topeka- Tilton High School, 

and McCullough Attendance Center, as these schools are presently 

In 

constituted and as presently operated under court order. 

    

    

    

    

    

Signature Address 

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| Personally appeared before me, the undersigned 

ity in and for said state and county, O. R. CROSS, who first 

being duly sworn states upon his oath as follows: 

vy name is O, . Cross. I reside in Monticello, 

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motion to 

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i Iv 3 cr - o  - -~ A wo involved in this matter a adversely and 
PRE Af og 4 ha a ~ - : +h id - 

aliected 11 the rel notion Tor 

   
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® 

IN THE 

UNITED STATES COURT OF APPEALS 

FOR THE FIFTH CIRCUIT 

UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF MISSISSIPPI 

UNITED STATES OF AMERICA, 

Plaintiff- Appellant 

Court of Appeals 

Nos. 28030 and 

VS. 28042 

D. C. Civil Action ' 
No. 2216 

LAWRENCE COUNTY SCHOOL 

DISTRICT, et al,, Defendants- Appellees 

RESPONSE OF 

INTERVENER-DEFENDANTS 

TO MOTION FOR SUPPLEMENTAL RELIEF 
  

The intervener-defendants,who are identified in their 

motion to intervene as defendants filed simultaneously herewith, in 

their own right and on their own behalf and on behalf of their respective 

children and wards and on behalf of all others similarly situated, 

file this response to the motion for supplemental relief filed herein on 

or about January 7, 1970, by NAACP Legal and Educational Defense 

Fund, Inc. 

l. Intervener-defendants admit paragraph 1 of said motion. 

However, they deny the implications that the underlined words, providing 

that no suggested modification may be submitted to Judge Russell before 

March 1, 1970, have any application to the issues now pending before 

the court. 

2. Intervener-defendants admit paragraph 2 of said motion 

for supplemental relief and aver affirmatively that the original HEW 

plan which was ordered to be implemented by this court's order of 

November 7, 1969, did contain grievous errors demanding immediate 

correction. Pursuant to the invitation of this court in the pre-order 

conference, the defendants-appellees moved the court for a modification 

 



  

of its order of November 7, 1969, so as to correct said grievous 

errors, and conferences were held with officials and representatives 

of the United States Department of Health, Education and Welfare and 

the United States Justice Department who, after farther investigation 

and consideration, agreed and approved the proposed modification and 

thereupon the Court of Appeals entered an order on November 26, 1969, 

modifying its order of November 7, 1969, so as to amend paragraph 2 

of the HEW plan to the limited extent set forth therein and further 

ordered implementation of the plan as thus amended. Said order of 

November 26, 1969, was entered before the effective date of the 

implementation of the plan and said original order of November 7, 1969, 

as amended by order of November 26, 1969, constitutesthe basic original 

order of the Court of Appeals setting forth the plan of desegregation 

for Lawrence County School District and requiring effectuation and 

implementation thereof not later than December 31, 1969. 

3. Inteverner-defendants deny paragraph 3 of said motion. 

4, Inteverner-defendants deny that the person signing 

affidavits attached to said motion are representative of the Negro citizens 

of Lawrence County and deny that their views represent the views of the 

vast majority of such citizens. The inteverner-defendants respectfully 

aver and point out to this court that the rights and privileges of all 

citizens of Lawrence County are involved and should be considered by 

this court, especially the constitutional rights of the children who are 

attending school in the county and who will be adversely effected by the 

relief sought by said motion for supplemental relief. 

5. Inteverner-defendants deny paragraph 5 of said motion. 

6. Inteverner-defendants deny paragraph 6 of said motion 

and they aver on the contrary that orders of the United States Court of 

Appeals for the Fifth Circuit do not depend for their legality upon 

 



  

endorsement or approval of any particular segment of any community 

and no aliegod community or segment of community or committee has 

any veto power over the lawful orders of this court. Inteverner- 

defendants again aver respectfully that the rights of all citizens of 

Lawrence County must be considered, especially the rights of the 

children attending schools in Lawrence County School District and the 

parents and guardians having primary responsibility for their eduction 

and welfare. 

7. Inteverner-defendants deny each and every allegation 

of paragraph 7 and subparagraphs a, b, and c thereof said forth in said 

motion. 

8. Inteverner-defendants deny paragraph 8 of the motion 

and they expressly deny that any school has been re-opened or that any 

school has been closed, as represented to this court by paragraph 8 of 

said motion. On the contrary, it is respectfully averred that all schools 

in Lawrence County at the time of the entry of the court's order are 

still being operated and absolutely no schools whatsoever have been 

closed, the allegations of said motion to the contrary notwithstanding. 

9. Inteverner-defendants deny that the order of the Court 

of Appeals entered November 26, 1969, which modified its order of 

November 7, 1969, was such a modification as was contemplated by 

that portion of the order of November 7, 1969, which directed that 

suggested modification be submitted to Judge Russell only after March 1, 

1970. On the other hand, the modification of November 26, 1969, was 

made by the Court of Appeals itself and, it is respectfully submitted, 

the effect is precisely the same as if it had been set forth in the original 

order as one of the exceptions similar to those specifically provided in - 

said order with respect to school districts and school systems in Pike 

County, Madison County, Wilkinson County, and Quitman County, which 

 



  

exceptions were originally incorporated in said order of November 7, 

1969. Inteverner-defendants aver, therefore, that it is not appropriate 

in this case to place the burden of proof upon Lawrence County School 

District, as requested in the prayer to said motion for supplemental 

relief and as directed by the order of the Court of Appeals entered 

January 12, 1970 (which order, we believe, through inadvertence or 

misaprehension as to the nature of the modification set forth in said 

motion for supplemental relief, placed the burden of proof in the 

hearing upon the defendants to demonstrate that the ''subsitute plan 

was devised and promulgated for educational purposes only). The 

present posture of the case is that the Lawrence County School District 

has fully complied with the order of the Court of Appeals and it is not 

now asking this court to take any action whatsoever or to make any 

further modifications of its order. The court is thus faced with the 

anomalous situation that under the order of January 12, 1970, the 

burden of proof has been placed upon Lawrence County School District 

to support the basic order of the Court of Appeals which has already been 

entered and which has been and is presently being complied with by the 

Lawrence County School District. On the contrary, the movant, NAACP 

Legal and Educational Defense Fund, Inc., is the party who seeks 

affirmative action of this court and they seek a modification of the order. 

Consequently, the burden of proof rightfully should be placed upon those 

movants, not upon the defendants. Inteverner-defendants, therefore, 

respectfully move the District Court, if it has the power, or if not, the 

Court of Appeals for the Fifth Circuit, to modify its order of January 12, 

1970, so as to place the burden of proof in this hearing upon the movant, 

NAACP Legal and Educational Defense Fund, Inc. 

10. In addition to the affirmative allegations contained 

in the foregoing paragraphs, the intervener-defendants respectfully show 

unto the court the following facts: 

 



  

(a) The Lawrence County School District has fully and 

faithfully complied with the plan of desegregation for its schools as di- 

rected and ordered by this court. All schools have been integrated as 

to student assignments, faculty assignments and all student activity 

programs such as athletic program, band, chorus and similar student 

extracurricular activities. Students are assigned to schools within 

their respective geographical areas without regard to race and no student 

is denied admission to such school or denied participation in any school 

activity on account of race. There are seven schools in Lawrence County 

and of these two schools formerly had all Negro student bodies and all 

Negro faculties. The remaining five schools formerly had predominantly 

White student bodies and White faculty. Today all seven schools are 

operating with fully integrated student bodies composed of both Negro and 

White students and fully integrated faculties composed of both Negro and 

White teachers. Two of the schools have Negro principals. The ratio of 

White and Negro students, teachers and principals is substantially in 

accordance with the ratio of White and Negro students in the entire school 

district. Although the plan of desegregation ordered by this court is 

opposed by and is not agreeable to the vast majority of students, parents 

and teachers, both White and Negro, they have and will continue in good 

faith to exert every effort to comply with the plan and to make it work 

and if permitted to continue without interference those responsible for 

the operation of an adequate school system in Lawrence County will be 

successful in its continued operation. 

(b) The United States has now filed its response to the 

motion for supplemental relief. It states that the desegregation plan 

presently employed by the defendant school district has effectively de- 

segregated the past dual school system in Lawrence County and that the 

interest of the United States is satisfied since it has been shown that the 

school district has developed and implemented an adequate system. 

 



  

(c) Historically there have been three main centers 

of population, education and civic activity in Lawrence County. The 

largest was the county seat, Monticello. The other two were New Hebron 

and Topeka-Tilton. For more than half a century high schools have been 

operated at each of these centers and, in addition, an all Negro high 

school was operated in Monticello. These high schools, as is typical 

of rural counties probably throughout this country, not only have provided 

a central point for education, training and development of the children, 

but also has centers for civic and cultural activities of their respective 

communities. This has permitted not only the school children themselves 

to become better acquainted with their neighbors, by attending school with 

children who live in the same area, but it has also permitted the parents 

of children living in the same general area to become acquainted and to 

share in various civic and cultural activities of the community as well as 

school related functions and activities. The continued operation of high 

school facilities at these three centers of activity in the community will 

substantially improve the relations of all citizens within the county. 

(d) The modified desegregation plan as approved and 

ordered by this court and implemented by the school district puts into 

actual effective practice the national policy of the preservation and 

maintenance of neighborhood schools as recently announced by the 

President of the United States. On the other hand, the original HEW 

plan, now sought to be reinstated by the motion for supplemental relief, 

would be destructive of the concept of neighborhood schools and would 

be contrary to the national policy as announced and promulgated by the 

President. 

(e) The Monticello High School, New Hebron High 

School and Topeka- Tilton High School were designed, constructed and 

equipped as total high school units, including the particular type of 

physical facilities required for education of Grades 9 through 12, 

- BAe 

 



- # 

  

including laboratories, library, equipment, athletic fields with lights 

for night athletic activities, dressing rooms, large parking areas and 

ample land for further expansion. These facilities are not well suited 

for grades 1 through 8 as provided in the original HEW plan and to 

return to that proposal would require abandonment of expensive facilities 

at great loss to the taxpayers of the county. The operation of three 

separate high schools instead of one as proposed by said motion very 

substantially broadens the base of student activities and the opportunity 

for student participation in all phases of the school activity including 

extracurricular activities such as chorus, dramatics, band, student 

government, football, track, basketball, baseball and other sports 

activities and results in a greater benefit to more students than if these 

activities were restricted to only one school and resulting limited 

opportunity for student participation. Monticello High School is the 

newest and best equipped high school in the county and its physical 

facilities are far superior to McCullough School. It is much better 

suited for operation of a high school than is McCullough School and on 

the other hand it is much less suited for operation of a school containing 

only grades 7 and 8, as proposed by said motion. 

(f) Many of the intervener-defendants live close to 

and within walking distance of the New Hebron and Topeka- Tilton 

schools and many of them own homes located nearby for the express 

purpose of permitting their children to attend these schools. The granting 

of the relief sought by said motion would require these children to be 

transported by bus long distances from their homes and from their 

neighborhood schools and would require many of them to ride school 

buses for long periods each day, some of them two hours or longer each 

day, which would result in a waste of time and energy which should be 

devoted to school study. Moreover, the expensive and increased busing 

which would be required by the original HEW plan would constitute an 

 



  

extremely heavy financial burden upon the school district which it is 

lnRan.e 10 bear, 

(g) Those students in grades 9 through 12 now attending 

1 

either Monticello High School or New Hebron High School or Topeka- 

T'ilton High School have the constitutional right to attend schools 

constructed and operated near their places of residence and to force 

these children to be transferred to one high school only at McCullough 

™ de School in the Town of Monticello, solely for the purposes of desegregation, 

rey ART Sha RRC ee Ss J ATTEN RCI, (Ee i 5 pie mor Ea pe tS CSTE ST DL Sei ; WR 
Oi tAdelr Cconsiituiiona: 1rignts and will deprive them ol tnelr 1 ight to attend 

z EE ER ee SE SI i ea eS See Sr TS EE SIDE ee 3 
SCO! SOLiLely pecallse Or race. lhiese students ana thelr respective 

varents and cuardians will. therefore. be deprived of their 1il : 
pa lc lies a lil gual Clans Will, le reiroy ec, Pe aeprived Ox thelr liberty and 

ll CE SP dn DL ER a LE ER I ey i RR SIE e " : 
property withouil que process ol aw ana wil. deny taemm edual rotection E L J & 2 

Si he El I a, Bi SR RE an ln SC LT Bel Yn dy gi 2 Ml £ . 
OI .aWws guaranteed Dy tiie Constitutions oi the United States of America 

Bn on Ch od N & << 
ana of the H>tate OX MViISS1ISSIDDIL. 

33 EN a ATR r a ed +S gE «1. These intervener-defendants adopt the response 

tr Crrinti nn thr re IRR ATH enta rE pall al fied hare in Kar v1 ATS +. 
LO ITR0O1ti0on 1o1 StUuphlernientia relieir rLiiecd herein oy Lawrence county 

School District together with all of the supporting affidavits filed there- 

with, and make all of the same a part hereof for all purposes as if fully 

set forth and copied herein. In addition, supporting affidavits to this 

oo
 

. Intervener-defendants, while supporting the 

nocLtian at dhe T ovwranrnen Cavmnbcr Seolhmel TY atime sib rg ee] position of the Lawrence County School District and opposing said 
olf 

motion for supplemental relief, hereby reserve unto themselves, and 

4 oy = abe Ty on omy ATE An cnt rate tho wich Bow: Che ony oy srs Yo vg Fa to each of them, and do not waive, the right hereafter to seek further 

Yn GAS RATIT SEN Fo ar Pg a pv TE . ody Poy PL ay, modifications of said desegregation plan and the orders of this court. 

5 

WHEREFORE, interverner-defendants pray that the 

  

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Fagniy TREE idly MEREEIE RSI RE, Sh TA A [ T nceval Bvsr Tas dor Nin ToT eal on i 5 Illed herein by NAACP l.egal and Educational Defense Fund, Inc. 

  

  

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i. W. rieidelberg Fe 4 - 

Post Office Box 1070 

  

attiesburg, Mississippi 

Of Counsel for Interverner-D ® Hh
 

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mm A m i we \ i NY y 8 ~N T kT 1 T 

STATE B MISSISSIPPI 

COUNTY OF LAWRENCE 

DAVIT OF O,.R. CROSS 

  

  

the undersigned 

  

authority in and for said state and county, O. R. CROSS, who first 

oy me Deing auly SWOrn states upon his oath as follows: 

My name is O. R. Cross. I reside in Monticello, 

  

1 ayia . Ty ; ; Fount Ta Lh ld} SG DL aid 
ia WIrence OUiLy, IVLL ml a TITY L'anl-one ol tne appli ans 1 

. (Jf rma fe SR RE Gy (Cet ly Py te oy ~ 
CIE notion to intervene as deifendants filed herein and one of 

We 54 7 ll et Diam hl on ve zs tT ATR Er Fa rs vn pe § rv =F ] 
thie intervener—-celfendantis ‘173 (ie response to motion ior suppie- 

mental reli1er atracneg nereio. 

res ently lain eng aged In the 1h surance business h ithe 

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remo SE Ply Si RES EA Ty fe ERR bal Ihe Ton VO TY i of a child enrolled in the Lawrence Count 

  

mT ATTY TY or Arye od ho a EGER SPE ga TI, Ba SEE) Pe So lit, rT 1 YL 
oCRo0OL t)isTT E WiOo 18 Vitalily interested 1 the 1ssuec involved 1n 

TE I BR I LT RII SED © ORR, Sra NE Sol SANA, SR Te i Je ORR 
EAS ITnatliey ang Wno will be aogvel Seely and dgdeirimenlta 

1th e rellel SO! Supp.iéinenial r 
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i 1 . l L . yi i 1 3 - Aornialo ren i, oy A A Py fd ay yar CT SE eT 
lhe denlais and averments contained in tne attached 

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information and belief 1RIorInation a22nG oesrierl., 

  

lief are true to the best of my knowledge, 

  

O., R\ CROSS 

AR Tigusine wis 
SWOI'n To ana suonscriped ‘ore me on this [J day of     

  

  

  

  

A i BA RR Te ) 
3 Ly LOoXNIrnission: us P1lI es: V4 >