Answers to Interrogatories

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JAMES N, KINCANON 

CITY ATTORNEY 

H. BEN JONES, JR. 

ASSISTANT CITY ATTORNEY 

    

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IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF VIRGINIA 

ROANOKE DIVISION 

  

CYNTHIA D. GREEN, etc., et al., 

Plaintiffs, 

zz, CIVIL ACTION NO. 1093 

SCHOOL BOARD OF THE CITY OF 
ROANOKE, et al., 

Defendants. 

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ANSWERS TO INTERROGATORIES 
  

Now come the defendants, School Board of the City of Roanoke 

and its Superintendent of Schools, by counsel, and said Superin- 

tendent of Schools of the City of Roanoke having been duly sworn, 

in response to the interrogatories served May 19, 1967, upon said 

defendants in the above case, makes the following answers and 

responses: 

 



  

§ : 

: 

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1. List with respect to each school in the Roanoke City F 

School System, as of the most recent date for which 

N
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figures are available, (a) the number of white pupils 

enrolled at each grade level and (b) the number of Negro 

pupils enrolled at each grade level. 

  

Br 

 



  

  

   
   

  

    

  

—— SA —————— - at oie a 

| Gradel ‘| Grade 2 | Grade 3 Grade 4 f Grade 5 Grade 6 Spec. Ed. Total 

SCHOOLS : i : : § He : 

(Elementary) WN T qW No TT IW NT WwW NN T iW NT WN T iW N TIW N T 

Belmont 15. 2 69 76 65 67 16 430 

Crystal Spring 75 B5 83 70 88 64 465 

Fairview 82 p 1 83 80 85 65 426 

Fishburn Park 35 28 27 32 31 25 178 

Forest Park 05 31 126. 183-18 106 178 16 91 [96 26 122 189 231121 86 14 100 529 128 657 

Garden City 49 51 52 58 40 42 292 

Gilmer 34 40 35 29 28 46 10 222 » 

Grandin Court 25 31 28 42 38 40 204 

Harrison 70 74 71 68 76 79 11 449 « 

Highland Park 88 73 67 91 69 67 14 469 

Huff Lane 59 50 53 60 57 56 14 349 

Hurt Park 30 45 46 36 25 28 210 . 

Jamison 100 79 84 110 87 79 31 570 

Lincoln Terrace 57 52 72 73 49 53 * 158(7th] 414: 

Loudon 1. 88 89 97 89 77 17 98-99 1.72 73 3 521 524 

Melrose 7 96 103 5 110 115 {11.96 107 2 130 132 11 8091 7 81 88 |1 13 14] 44 606 650 

Monterey 42 38 3] 49 42 39 241 

Morningside 55. 65 84 56 68 52 380 

Oakland 88 59 86 71 64 90 458 

Preston Park 80 60 64 63 65 67 399 

Raleigh Court 48 48 51 49 53 42 291 

Round Hill 58: 2 60 {51 1 52 {53 4 57 | 66 66 |70 1 71}.63 2 65 361 10 371 

Tinker 27 315 22 32 19 18 133 

Virginia Heights 87 88 87 78 97 105 542 

Wasena 49 52 54 69 77 67 368 

Washington Heights [26 32 29 31 29 30 }77 

West End 45 17 62 135 10 45 {44 5 49 | 44 8 52137 15 B52) 35 22 57 [61 7 68§30]1 84 385 

Westside 39 34 31 35 34 48 221 

* Lincoln Terrace has 7th grade|. The enrollment (158) enflered in Special Education column is 7th grade. There is no 

. Speciall Education class at Lincoln Terrace. 

at | Februgry 1, 1967                 
 



  

SCHOOLS 

(Secondary) 

Addison High School 

William Fleming HS 

Patrick Henry HS 

Jefferson High Schod] 

Breckinridge Jr.HS 

Stonewall Jackson 

IL.ee Jr. HS 

Monroe Jr. HS 

Booker T. Wash.JHS 

Woodrow Wilson JHS 

  
306 
1297 
156 
179 

47 203 

94 273 

189 

  

Grade 8 

Winey 

321.2 323 

228 

192 $8 250 

185 94 279 

248 

358 

  

356 

293 

170 

183 

152 

394 

  

Grade 3 

29 212 

96 248 
112 

  

    

  

    

  

Grade 11 Grade 12 |Special Ed. Total 

¥ NTlw nN T|W N TWN 

203 230 725 

361 66 427] 388 9 397 1188 140 1328 

309 308 1289 

283 . 32315 .257 3 2601 7 B60 75 935 

920 : 2. 922 

14 709 

12 4 161543 138 681 

6 10 161522 294 816 

11 560 © 

752 

February|l, 1967     
 



  

Give the estimated number of white pupils and the estimated 
number of Negro pupils who will be attending each school 
during the 1967-68 session. 

The attached sheets were presented to the Roanoke City School 
Board on February 28, 1967, for the Housing of Pupils for 
1967-68. The information includes the names of the schools, 
the grades to be housed, the rated capacity of each school, 
the 1966-67 enrollment, and the estimated enrollment for 
1967-68. 

An estimate must be based on past experience, on births six 
years prior to those entering school for the first time, on 
previous drop-out rate, and other factors. 

All pupils have been assigned to the schools in their attend- 
ance area for next year. However, neither the principals 
nor the central office has the information on the pupils as 
to race. 

 



   



   



   



  

3. State the number of white and Negro teachers and other administrative and 
professional personnel employed at each school during the 1966-67 school year. 

Schools 

Addison 
William Fleming 
Patrick Henry 
Jefferson 

Breckinridge 
Stonewall Jackson 
Lee 

Monroe 

Booker T. Washington 
Woodrow Wilson 

Belmont 

Crystal Spring 
Fairview 

Fishburn Park 

Forest Park 

Garden City 
Gilmer 

Grandin Court 
Harrison 

Highland Park 
Huff lane 

Hurt Park 
Jamison 

Lincoln Terrace 
Loudon 

Melrose 
Monterey 
Morningside 
Oakland 

Preston Park 

Raleigh Court 
Round Hill 

Tinker 
Virginia Heights 
Wasena 

Washington Heights 
West End 
Westside 

TOTAL 

Administrative 

White 

Teachers 
  

F
E
 

nd
 

M
D
D
O
V
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(19) 

(23) 

2 

35 (3893) 

173 
18 

15 
6 

21 

21 
15 

13 
16 
14 
12 
16 

5 
20% 
1 

6 
163 
8 (3233) 

  

Negro 

Administrative Teachers 

2 L6% 
2 

4 

2 

2 a 
(4) (873) 

3 

1 10 

1 21 

2 0 

1 18 

1 18 

10 

 § 

(5) (88) 
5 not assigned to a specific school 

718 9 1753 

PLL 

 



  

Le For each of the school years 1964-65, 1965-66, and 1966=67 give the 
number, and for the school year 1967-68 give an estimate of the number, of 
(a) white high school teachers, (b) Negro high school teachers, (c) white 
elementary school teachers and (d) Negro elementary school teachers, whose 
employment by the defendant school board began or will begin. 

White Secondary 

Negro Secondary 

White Elementary 

Negro Elementary 

Total 

1964-65 

367 

81 

318} 

87 

853% 

1965-66 
369% 

85 

316 

86 

8563 

1966-67 

3903 

893% 

1967-68 

390% 

8863 

 



  

5. File a copy of the plans and procedures last published governing enroll- 

ments and transfers of pupils and give the date and manner of publication. 

The attached information shows a copy of the letter sent to every 
pupil in May 1966, with the procedure to the principals. A copy of the 
Plan of Desegregation is included. 

Also a copy of the letter sent to every pupil who was to 

a. enter school for the first time -- this includes preschool 
pupils and those who will transfer in to the city, 

b. be promoted from elementary school to junior high school, 

c. be promoted from junior high school to senior high school, 

for May 1, 1967, and a copy of the procedure for the principals. 

 



   



 





   
9. Violations To Be Reported     
      

rl ret ay desecregati on plan for any school official ~ teacher to nfliiancre threaten or oCNOrrn ants 
LAU Ji UuUl OCI THaally plall LI ally U 

~41 an th the exercise of any rights ander this plan. Tt is also a violation of Federal regulations 
COLLIICCULLIVUIL WILLD UIT TATIULS Ul Ly JS Il. LL 

ror +n intimidate threaten coerce Tetali ate Ar discriminate against any individual for theo DUIDOSE nf 
150 WO LUIIUAilC,, Lica, CUCTIUC, ola \ ~ 101 § 

int or ith +h desegreg ration of Nl ur school s Qvx7 stem Anv noranNnn havin oO anv kitow ledeoe Ff anv violation nf these 
% ) LIIT UCD 1Cgalilll U1 UU C1001 ° 15C U 

  

es shot uld ronnrt th 
| UL111LIULLS t LOUPUL UL Lic 

facts immedi ately be mai il or phone io the Equ al Fducational Opportunities Program 

    

  

U. S. Office of Education, Washington, D. C., 20202 (telephone 202—-962- 0333). The name of any person reporting 

any violation will not be disclosed without his consent. Any other violation of the des segregation plan or other 

discrimination based on race, color, or national origin in the school system is also a violation of Federal requirements 
and should likewise be reported. Anyone with a complaint to report should first bring it to the attention of local 

school officials, unless he feels it would not be helpful to do so. If local officials do not correct the Violation 

promptly, any person familiar with the facts of the violation should report them immediately to the U. S. Office 

of Education at the above address or phone number. 

In order to implement the Plan of Desegregation, attendance zones havebeen established by the School Board 

for each school. According to the areas and since you live at the address indicated, your child will attend 

NAME 
  

HOME ADDRESS 

SCHOOL 

  

  

SCHOOL ADDRESS 
  

for the 1966—67 school year. 

Any exceptions to this placement may be requested, in writing within a month, if they conform to the conditions 

set forth in this letter in Item 3 — Transfer To School in Another Zone. 

If you move from your present address, placement in the school of that new attendance area must be made. 

    

  

May 1, 1966 mtn) of Schools 

Graphic Arts Department— Jefferson Senior High School 

 



ROANOKE CITY SCHOOL BOARD 
217 W. Church Ave. 

Roanoke, Virginia 

NOTICE OF SCHOOL DESEGREGATION PLAN UNDER TITLE VI OF THE CIVIL RIGHTS 
ACT OF 1964 

This notice is made available to inform you about the desegregation of our schools. Keep a copy of this notice. It 
will answer many questions about school desegregation. 

1. Desegregation Plan in Effect 
The Roanoke City public school system is being desegregated under a plan adopted in accordance with Title 
VI of the Civil Rights Act of 1964. The purpose of the desegregation plan is to eliminate from our school 
system the racial segregation of students and all other forms of discrimination based on race, color, or national 
origin. Your school board and the school staff will do everything they can to see to it that the rights of all 
students are protected and that our desegregation plan is carried our successfully. 

. Non—Racial Attendance Zones 
Under the desegregation plan, the school each student will attend depends on where he lives. An attendance 
zone has been established for each school in the system. All students in the same grade who live in the same 
zone will be assigned to the same school, regardless of their race, color, or national origin and regardless 
of which school they attend now. 

Transfer to School in Another Zone 
A student may transfer from the school to which he is assigned only under the following conditions: A 
student who requires a course of study not offered at the school serving his zone, or who is physically 
handicapped, may be permitted, upon his written application, to transfer to another school which is designed 
to fit, or offers courses for, his special needs. Transfers for any other reasons will not be permitted. 

Notification of Assignment : » 
On May 15, 1966 the parent, or other adult person acting as parent, of each student enrolled in this system will 
be sent an addition to this letter a statement telling him the name and location of the school to which the 
student will be assigned for the coming school year. A letter will also give information an any school bus service 
provided for the student’s neighborhood. (A copy of this notice will be enclosed with each letter.) The same 
letter and notice will be sent out on the above date for all children the school system expects to enter the 
school system for the first time next year. (This includes children entering first grade.) If the school system 
learns of a new student after the above date, it will promptly send the student’s parent such a letter and a 
copy of this notice. 

. Maps Showing Attendance Zones 
Maps showing the boundary lines of the attendance zones of every school in the school system are freely available 
for inspection by the public at the Superintendent’s office. Individual zone maps are available at each school. 

. Revision of Attendance Zones Boundaries Co 
Any revision of attendance zone boundaries will be announced by a prominent notice in a local school paper 
at least 30 days before the change is effective. 

. All Other Aspects of Schools Desegregated 
All school—connected services, facilities, athletics, activities and programs are open to each student on a 
desegregated basis. A student assigned to a new school under the provisions of the desegregation plan will 
not be aabiect to any disqualification or waiting period for participation in activities and programs, i cluding 
athletics, which might otherwise apply because he is a transfer student. All transportation furnish x by the 
school system will also operate on a desegregated basis. Faculties will be desegregated, anc ta 
Err will lose his position because of race, color, or national origin. This includes any case where less 
staff is needed because schools are closed or enrollment is reduced. 

(0 

. Attendance Across School System Lines 
No arrangement will be made or permission granted by this school system for any students living in the 
community it serves to attend school in another school system, where this would tend to limit desegregation, 
or where the opportunity is not available to all students without regard to race, color. or national origin. No 
arrangement will be made or permission granted, by this school system for any students living in an 
system to attend public school in this system, where this would tend to limit desegregation, or whe: 
is not available to all students without regard to race, color, or national origin. 

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REVISION OF DESEGREGATICN PLAN 

Presented to and Approved by the 

Roanoke City School Board 

The School System has operated for the 1963-1964 session in 

accordance with the Plan of Desegregation as adopted by the Roanoke 
<9 g Pp y 

City School Board and as approved by Judge Michie in the spring of 

1963. 

A memcrandum was received from Judge Michie regarding this 

plan on September 6, 1963. In this memorandum he set forth two 

areas of controversy between the plaintiff and the defendant which had 

been affected by the Jackson et al v. School Board of the City of 
  

Lynchburg (No. 8722, Decided June 29, 1963) 
  

1. desegregation of faculty and staff 

2. timetable for desegregation . 

In regard to a revised timetable for desegregation, the following 

proposal is submitted: 

I(a) 

] (c) 

  
  

Commencing with the 1964-65 school year all classes 

in Grades One, Two, Three, Four, Seven, and 

Eight would be operated on a desegregated basis. 

Commencing with the 1965-66 school year, all classes 

in Grades One, Two, Three, Four, Five, Seven, Kight, 

Nine, and Ten would be operated on a desegregated 

basis. 

Commencing with the 1966-67 school year classes in 

all grades would operate on a desegregated basis.



oi Sh 

Revision of Desegregation Plan 
  

The following sections of the Plan as approved by Judge Michie would 

remain: 

II. The Superintendent of Schools shall, from time to 

time, estoblish attendance arzas basad solcly on the 

residence of the pupils and the location and capacity 

of the city schools. 

III. Except where a pupil is moving from the elementary 

to the junior high school level or from the junior high 

school to the high school level or has changed his 

residence, no pupil shall be required to transfer from 

the school he attended for the 1962-63 school year. 

IV. As a temporary measure only and until completion 

of the Plan for Desegregation, applications of pupils in 

grades not then wholly desegregated under this plan for 

a transfer to schools predominantly attended by members 

of another race shall be granted where space is available 

and the applicant: 

(a) resides closer to the school applied for than 

to the one assigned; and, 

(b) is at or above the fiftieth percentile of the class 

to which he seeks admission both in scholastic 

aptitude and achievement.  



  

Revision of Desegregation Plan 
  

V. Other transfers from one school to another during 

the school year shall be solely at the discretion of the 

| Superintendent but without discrimination among races. 

VI. Each school year hereafter the Superintendent shall 

i 

| assign pupils in accordance with this plan and notify the 

| parents or guardians of the pupils of such assignment 

by July 15th preceding the commencement of the school 

year. Any person dissatisfied with the assignment made 

by the Superintendent shall notify the Superintendent of 

such dissatisfaction no later than August lst, In the 

event the assignment madeby the Superintendent after such 

protest is still unsatisfactory to the pupil or his parents, 

the pupil shall have the right ™ appeal the assignment 

for consideration by the School Board at its annual 

August meeting. 

March 9, 1964 

 



    
Desegregation of Faculty and Staff 

Presented tc the 

Roanoke City School Board 

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The memorandum of September 6, 1963, from Judge Michie 

stated that ''the School Board is to study the problem of how best to 

work out a method for the assignment of faculty and staff on a non- 

discriminatory basis and come forward with a plan or resolution on 

that subject as soon as possible ......... it is clear that some 

concrete steps must be taken by the school year of 1964-65." 

In view of the directive from Judge Michie that some concrete 

steps must be taken by the school year of 1964-65, it is suggested 

that a beginning be made for desegregation of faculty for the ensuing 

school year. It would appear that with the extent of pupil desegrega- 

tion in the Melrose Elementary School that some desegregation of 

faculty should be considered. 

A plan for desegregation of faculty and staff is under considera- 

tion by the school administration. The responsibility for a plan for 

the Roanoke City Schools will, of necessity, have to be shared by 

many individuals in the interest of pupils, teachers, schools and 

community. Faculty and staff desegregation must be geared to 

teacher retirement, resignations, and the selection and assignment 

of new teachers on the basis of relative merit and qualifications. 

March 9, 1964   
 



ROANOKE CITY PUBLIC SCHOOLS 
Roanoke, Virginia 

Division of Educational Administration 

TO: Principals 

FROM: Dorothy L. Gibboney, Superintendent 

SUBJECT: Letters Indicating School Attendance 

We are sending you the letters to be completed and sent out to parents. 
PLEASE follow these directions: 

1. Make a carbon copy of each letter filling in the pupil's name, address, 
and name and address of the school he will attend. A letter must be 
completed for each pupil who will 

a. enter school for the first time -- this includes preschool 
pupils and those who will transfer in to the city; 

b. be promoted from elementary school to junior high school; 

¢. be promoted from junior high school to senior high school. 

2. Be certain that the address is accurate and that it is the residence 
of the parents -- not a relative's address. 

If you know a child is moving, use the new address. 

You will see that NO pupil will attend a school outside of the attendance 
area in which he resides UNLESS you secure clearance in writing. The 
letters should be written to me and Mrs, Heck will continue to handle the 
phone calls and correspondence on this. If an exception has been made 
for any pupil, please write on the carbon "EXCEPTION, LETTER DATED 

. Send both the original and the carbon copies of these letters to Mrs. 
Heck by Friday, May 19. Send them earlier if they are completed. The 
originals will be returned to you to enclose in the report card envelopes 
or to distribute if the pupils come for report cards. The original copies 
for children entering the first grade next year will be put in envelopes 
and should be given to an older brother or sister, or put in the mail. 

6. Please call Mr. Via or Mrs. Heck if you have questions. 

(You will note that we are not completing letters for those pupils who 
will continue in your school -- they are residing in your attendance 
area where they were assigned last year and will only move up a grade, 
or repeat the same grade.) 

DIG: dh  



   

  

9. Violations To Be Reported 
It is a violation of our desegregation plan for any school official or teacher to influence, threaten or coerce any 
person in connection with the exercise of any rights under this plan. It is also a violation of Federal regulations 
for any person to intimidate, threaten, coerce, retaliate or discriminate against any individual for the purpose of 
interfering with the desegregation of our school system. Any person having any knowledge of any violation of these 
prohibitions should report the facts immediately by mail or phone to the Equal Educational Opportunities Program, 
U. S. Office of Education, Washington, D. C., 20202 (telephone 202-962-0333). The name of any person reporting 
any violation will not be disclosed without his consent. Any other violation of the desegregation plan or other 
discrimination based on race, color, or national origin in the school system is also a violation of Federal requirements 
and should likewise be reported. Anyone with a complaint to report should first bring it to the attention of local 
school officials, unless he feels it would not be helpful to do so. If local officials do not correct the violation 

promptly, any person familiar with the facts of the violation should report them immediately to the U. S. Office 

In order to implement the Plan of Desegregation, attendance zones have been established by the School Board 
for each school. According to the areas and since you live at the address indicated, your child will attend 

NAME 

HOME ADDRESS 

SCHOOL 

  

  

  

SCHOOL ADDRESS 
  

for the]967 — 68school year. 

Any exceptions to this placement may be requested, in writing within a month, if they conform to the conditions 
set forth in this letter in Item 3 — Transfer To School in Another Zone. 

If you move from your present address, placement in the school of that new attendance area must be made. 

bi, % Lins. ~ 

: Dorothy L. Gibboney 
April 1967 Superintendent of Schools 

Graphic Arts Department— Jefferson Senior High School 

 



ROANOKE CITY SCHOOL BOARD 
217 W. Church Ave. 

Roanoke, Virginia 

  

NOTICE OF SCHOOL DESEGREGATION PLAN UNDER TITLE VI OF THE CIVIL RIGHTS 
ACT OF 1964 

This notice is made available to inform you about the desegregation of our schools. Keep a copy of this notice. It 
will answer many questions about school desegregation. 

1. Desegregation Plan in Effect 
The Roanoke City public school system is being desegregated under a plan adopted in accordance with Title 
VI of the Civil Rights Act of 1964. The purpose of the desegregation plan is to eliminate from our school 
system the racial segregation of students and all other forms of discrimination based on race, color, or national 

origin. Your school board and the school staff will do everything they can to see to it that the rights of all 
students are protected and that our desegregation plan is carried our successfully. 

2. Non—Racial Attendance Zones 
Under the desegregation plan, the school each student will attend depends on where he lives. An attendance 
zone has been established for each school in the system. All students in the same grade who live in the same 
zone will be assigned to the same school, regardless of their race, color, or national origin and regardless 
of which school they attend now. 

3. Transfer to School in Another Zone 
A student may transfer from the school to which he is assigned only under the following conditions: A 
student who requires a course of study not offered at the school serving his zone, or who is physically 
handicapped, may be permitted, upon his written application, to transfer to another school which is designed 
to fit, or offers courses for, his special needs. Transfers for any other reasons will not be permitted. 

4. Notification of Assignment : : : 

On May 15, 1967 the parent, or other adult person acting as parent, of each student enrolled in this system will 
be sent in addition to this letter a statement telling him the name and location of the school to which the 
student will be assigned for the coming school year. A letter will also give information an any school bus service 
provided for the student’s neighborhood. (A copy of this notice will be enclosed with each letter.) The same 
letter and notice will be sent out on the above date for all children the school system expects to enter the 
school system for the first time next year. (This includes children entering first grade.) If the school system 
learns of a new student after the above date, it will promptly send the student’s parent such a letter and a 

copy of this notice. 

5. Maps Showing Attendance Zones 
Maps showing the boundary lines of the attendance zones of every school in the school system are freely available 
for inspection by the public at the Superintendent’s office. Individual zone maps are available at each school. 

6. Revision of Attendance Zones Boundaries 
Any revision of attendance zone boundaries will be announced by a prominent notice in a local school paper 
at least 30 days before the change is effective. 

7. All Other Aspects of Schools Desegregated 
All school—connected services, facilities, athletics, activities and programs are open to each student on a 
desegregated basis. A student assigned to a new school under the provisions of the desegregation plan will 
not be subject to any disqualification or waiting period for participation in activities and programs, including 
athletics, which might otherwise apply because he is a transfer student. All transportation furnished by the 
school system will also operate on a desegregated basis. Faculties will be desegregated, and no staff 
member will lose his position because of race, color, or national origin. This includes any case where less 
staff is needed because schools are closed or enrollment is reduced. 

8. Attendance Across School System Lines 
No arrangement will be made or permission granted by this school system for any students living in the 
community it serves to attend school in another school system, where this would tend to limit desegregation, 
or where the opportunity is not available to all students without regard to race, color. or national origin. No 
arrangement will be made or permission granted, by this school system for any students living in another school 
system to attend public school in this system, where this would tend to limit desegregation, or where the opportunity 
is not available to all students without regard to race, color, or national origin. 

 



STATE OF VIRGINIA § 

CITY OF ROANOKE § 

I, Dorothy L. Gibboney, Superintendent of Schools of the City 

of Roanoke, in the Commonwealth of Virginia, being first duly sworn, 

make oath that the foregoing answers made to the interrogatories 

served May 19, 1967, in the abovestyled case, are true, according to 

the best of my knowledge, information and belief. 

Given under my hand this 6th day of June, 1967: 

\) 
”\ BY 4 

wl 0. AAA A ~ 7\ ; “Ze Lt Ef) nll 

Dorothy L. Gibboney, 
Superintendent of Schools of the 
City of Roanoke 

  

SUBSCRIBED AND SWORN to by Dorothy L. Gibboney, Superintendent 
of Schools of the City of Roanoke, before me, the undersigned Notary 
Public, in and for the City of Roanoke, Commonwealth of Virginia, in 
my jurisdiction aforesaid, this 6th day of June, 1967: 

ma 

  “Notary Public 

My Commission expires: April 4, 1971. 

Ne cer rires 
James N. Kincanon, 
City Attorney 
215 Municipal Building 
Roanoke, Virginia, 24011 

  

Counsel for Defendants  



  

CERTIFICATE OF SERVICE 
  

This is to certify that on the 6th day of June, 1967, the 

foregoing Answers to Interrogatories were served upon S. W. Tucker, 

Esquire, c/o Hill, Tucker & Marsh, 214 East Clay Street, Richmond, 

Virginia, 23219, and upon James M. Nabrit, III, Esquire, 10 Columbus 

Circle, New York, New York, 10019, attorneys for the plaintiffs, 

by depositing the same in the United States mail, postage prepaid, 

addressed to them as indicated above. 

ISG 
  Jarles N. Kincanon, 
City Attorney 
Counsel for the Defendants 
215 Municipal Building 
Roanoke, Virginia