Draft Stipulation and Motion

    IN THE UNITED STATES COURT OF APPEALS
FOR THE SIXTH CIRCUIT

No

RONALD BRADLEY, et al.,
Plaintiffs-Appellees 
Cross-Appellants,

VS.
----- WILLIAM G. MILLIKEN, et al.,

Defendants-Appellants, 
--  --Cross-Appel1ees,

DETROIT FEDERATION OF TEACHERS, LOCAL 231, 
AMERICAN FEDERATION OF TEACHERS, AFL-CIO,

Appeal from the United States District Court 
for the Eastern District of Michigan 

Southern Division

STIPULATION OF THE PARTIES 
PURSUANT TO RULE 28(h), FEDERAL RULES OF 

APPELLATE PROCEDURE

The defendants having filed appeals in the above-styled

Defendant-Intervenor- 
Appellee,

and
DENISE MAGDOWSKI, et al.,

Defendants-Intervenor

case, and plaintiffs having filed a cross-appeal,



IT IS STIPULATED AS FOLLOWS:
1. Upon the filing of the record with this Court, 

defendants will file Briefs for Appellants within the time 
allowed by Rule 31(a) of the Federal Rules of Appellate Procedure.

2. Upon the filing of defendants' briefs under Paragraph
1 above, and within the time allowed, plaintiffs will file Appellees' 
Answer Brief and Cross-appellants' Brief.

3. Upon the filing of a brief by plaintiffs under Para­
graph 2 above, and within the time allowed, defendants will file 
Appellants' Reply Briefs and Cross-appellees' Answer Briefs, and 
defendant-intervenor, Detroit Federation of Teachers, will file 
Appellees' Answer Brief to Cross-Appellants' Brief.

4. Upon the filing of briefs by defendants under Paragraph 
3 above, and within the time allowed, plaintiffs will file Cross­
appellants' Reply Brief.

Ratner, Sugarmon & Lucas 
525 Commerce Title Building 
Memphis, Tennessee 38103

Nathaniel R. Jones 
E. Winther McCroom 
Paul R. Dimond 
Norman J. Chachkin
Attorneys for Plaintiffs-appellees, 
Cross appellants

George T. Roumell, Jr. 
Louis D. Beer 

Riley & Roumell 
7th Floor, Ford Building 
Detroit, Michigan 48226



Attorneys for Defendant Detroit 
Board of Education-Appellants, Cross­
Appellees

Eugene Krasicky
Seven Story Office Building 
525 West Ottawa Street 
Lansing, Michigan 48913

Attorney for State Defendants- 
Appellants, Cross-Appellees

Theodore Sachs ..
1000 Farmer
Detroit, Michigan 48226

Attorney for Defendant-Intervenor- 
Appellee

Alexander B. Ritchie 
2555 Guardian Building 
Detroit, Michigan 48226

Attorney for other Intervening- 
Defendants



IN THE UNITED STATES COURT OF APPEALS
FOR THE SIXTH CIRCUIT 

No.

RONALD BRADLEY, et al.,
Plaintiffs-Appellees, 
Cross-Appellants,

vs.
WILLIAM G. MILLIKEN, et al.,

Defendants-Appellants, 
Cross-Appellees,

DETROIT FEDERATION OF TEACHERS, LOCAL 231, 
AMERICAN FEDERATION OF TEACHERS, AFL-CIO,

Defendant-Intervneor- 
Appellee,

and
DENISE MAGDOWSKI, et al.,

Defendants-Intervenor.

Appeal from the United States District Court 
for the Eastern District of Michigan 

Southern Division

JOINT MOTION OF ALL PARTIES 
TO BE RELIEVED OF OBLIGATIONS UNDER 

RULE 30(b), FEDERAL RULES OF APPELLATE PROCEDURE



Each of the parties in this case, by undersigned counsel, 
respectfully moves the Court to enter an order relieving said parties 
of their obligations under Rule 30(b), Federal Rules of Appellate 
Procedure, to designate and cross-designate the appendix. As grounds 
for tnis motion, the parties respectfully show:

(1) Principal appellants (Detroit Board of Education 
defendants and State defendants)* have heretofore filed a motion 
under Rule 30(c), Federal Rules of Appellate Procedure, to defer 
preparation of the appendix until after the filing of briefs.

(2) Principal appellees (plaintiffs) have heretofore 
filed a motion for leave to proceed in this appeal on the original 
papers.

(3) All parties are in agreement that, should plaintiffs' 
motion to proceed on the original papers be denied, then defendants' 
motion to defer preparation of the appendix should be granted, for 
the reasons set forth in defendants' motion, as well as those set 
forth in plaintiffs' motion.

(4) All parties are informed that plaintiffs are preparing, 
for timely filing, a motion to dismiss the appeals in this cause and, 
should such motion be granted, any initial expense incurred in desig­
nating, cross-designating, and preparing an appendix at this juncture 
would be wasteful and unnecessary.

WHEREFORE, for the foregoing reasons, all parties respect­
fully pray that the Court enter an order relieving them of the obligations

*The parties have filed a stipulation pursuant to Rule 28(h), F.R.A.P., 
as to the order of filing briefs.

2



imposed by Rule 30(c), F.R.A.P., pending resolution by the Court 
of the motion to defer preparation of appendix and the motion to 
proceed on the original papers heretofore filed by some of the 
parties.

Respectfully submitted,

William E. Caldwell
Ratner, Sugarmon & Lucas 
525 Commerce Title Building

Nathaniel R. Jones 
E. Winther McCroom 
Paul R. Dimond 
Norman J. Chachkin
Attorneys for Plaintiffs

George T. Roumell 
Louis D. Beer 

Riley & Roumell 
7th Floor, Ford Building 
Detroit, Michigan 48226

Attorneys for Detroit Board of 
Education Defendants

Theodore Sachs
1000 Farmer Street 
Detroit, Michigan 48226

Attorney for Intervening-Defendant 
Detroit Federation of TEachers

Eugene Krasicky
725 Seven Story Office Building 
Lansing, Michigan 48913

Attorney for State Defendants



Alexander B. Ritchie
2555 Guardian Building 
Detroit, Michigan 48226

Attorney for Intervening-Defendants 
Denise Magdowski, et al.