Motion to Intervene as Party Plaintiffs

    ® » 

IN THE UNITED STATES COURT OF APPEALS 

FOR THE FIFTH CIRCUIT 

  

UNITED STATES OF AMERICA, 

Plaintiff-Appellant, 

VS. . NOS. 28030 
v and 28042 

HINDS COUNTY SCHOOL BOARD, et al., 

Defendants-Appellees. 

UNITED STATES OF AMERICA, 

Plaintiff-Appellant, d 
DISTRICT COURT 

VS. ACTION NO. 2216H 

LAWRENCE COUNTY SCHOOL DISTRICT, 

et al., 

Defendants-Appellees. ) 

) 
  

MOTION TO INTERVENE AS PARTY PLAINTIFFS 
  

The following motion is filed pursuant to Rule 24 of the 

Federal Rules of Civil Procedure. 

1. The following named children, represented by their 

parents, move this Court to intervene as party plaintiffs: 

a) Charles R. Williams and Frank Williams, repre- 

sented by their father, Lenza Williams; 

b) Delphine Denise Ross, represented by her father, 

Fnioch Ross; 

¢) Janice Bryant, Nevelyn Bryant, Columbus Bryant, 

Jr. and Clementa Bryant, by their father, Columbus Bryant; 

d) Pekola Flemings and Bruno Flemings, represer 

by their father, Josephus Flemings; 

 



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e) Vanessa Funches and Walerie Funches, represented 

by their father, Argustus Funches; 

f) Theodore R. Stewart and Wanda Stewart, represented 

by their nother, Helen Stewart; 

g) Ronald hartwell, Donald Hartwell, Veronica Hartwell, 

Tommie Hartwell and Diana Garner, represented by their mother, 

Mrs. Lester Hartwell. 

2. In support of this motion they allege: 

a) that they are black children enrolled in public 

schools located within the defendant school district; that the 

disposition of this action may impede and impair their ability 

to protect their right to a racially non-discriminatory school 

system; 

b) that at the time suit was filed by the United 

States they believed that their interests would be adequately 

represented; 

c) that it has become apparent to movants that the 

[ government no longer adequately represents their interests. 

WHEREFORE, the above named children respectfully move this 

Court to enter an order approving their intervention as party 

plaintiffs. 

January 7, 1970 Respectfully submitted, [fe 
| 

| ( \¢, x 5 \./ 
      

i ON v 

MELVYN R. LEVENTHAL 
REUBEN V. ANDERSON 
FRED L. BANKS, JR. 
JOHN A. NICHOLS 

538% North Farish Street 
Jackson, Mississippi 39202 

  

JACK GREENBERG 
NORMAN CHACHKIN 
JONATHAN SHAPIRO 

Suite 2030 
10 Columbus Circle 
New York, New York 10019 

 



  

CERTIFICATE OF SERVICE 
  

I hereby certify that on this 7th day of January, 1970, 

I caused to be served by United States mail, postage prepaid, 

a copy of the foregoing Motion to Intervene as Party Plaintiffs 

upon Honorable James S. i Post Office Box 493, Monticello, 

A \ a A 

Mississippi 39654. 

  MELVYN R. LEVENTHAL