Plaintiffs' List of Additional Exhibits and Proposed Evidence

     [||fe9a66ae-d326-4b0e-b304-5f5766fa402b||] IN THE 

UNITED STATES DISTRICT COURT 

FOR THE = Y 

WESTERN DISTRICT OF NORTH CAROLINA 

CHARLOTTE DIVISION 

  

JAMES E. SWANN, et al., 

Plaintiffs Appellees, 

Vv. 

CHARLOTTE~MECKLENBURG BOARD OF 

FDUCATION, et al., 

Defendants Appellants, CIVIL ACTION 

and NO. 1974 

HONORABLE ROBERT W. SCOTT, Governor of 

the State of North Carolina, et al., 

Additional Parties 

Defendants Appellants. 

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PLAINTIFFS' LIST OF ADDITIONAL 

EXHIBITS AND PROPOSED EVIDENCE 

  

  

At the hearing in this cause on February 5, 1970, the Court | 

advised the parties that "the record remains open for any showing 

that either party wants to make." The following exhibits are 

tended by plaintiffs pursuant to the permission so granted: 

l, "affidavit of Mr. D.:dJd. Park, Director of Transportation 

for the State Board of Education, with attached inite 

2, Affidevit of Mr. R. D, McMillan, Jr., State Purchasing 

Office of the Department of Purchase and Ccntracts for the State 

of North Carolina.   
 



      

3. Deposition of Dr. William C. Self, taken on February 

25, 1970, with attached exhibits. 

4. Deposition of My. J. D. Morgan, taken on Pebruary 25, 

1970, with attached exhibits. 

5. Budget of Mecklenburg County for the fiscal year 1969-70. 

6. Budget of the Charlotte—-Mecklenburg Board of Education 

for the fiscal year 1969-70. 

7. Summary of the State budget of the State of North Carolina 

for the 1969-71 biennium. 

8. Statement of expenditures by the State to the Charlotte- 

Mecklenburg public School System for the year ending June 30, 

1959, 

9. Financial report of the Charlotte-Ma2cklenburg Board of 

Education to the State Superintendent of Public Instruction for 

the 1968-69 school year. 

10. Supplemental financial report, ESCA and Headstart, of the 

Charlotte—-Mecklenburg Board of Education to the State Superinten- 

dent of Public Instruction for the 1968-69 school year. 

11. State budget for the State Board of Education for 1969-70 

and 1970-71. 

12. Biennial report of the State Superintendent of Public 

Instruction for the 1966-67 and 1967-68 school years, pages 127- 

333. 

13. Excerpts from the report of the Governor's Study 

Commission of the Public School System of North Carolina, dated 

1968.   
 



  

14. Excerpts from the article of Myer Weinberg, Race and 

Place, prepared for the United States Department of Health, 

    

Education and Welfare. 

i5. 

and Amendments to same as finally adopted 

Stat. §115-176.1. 

16. Article by Robert E. Phey, 

Education, reprinted from Popular Government, 

Copy of the House Bill of Representative James Carson 

and coded N.C. Gen. 

Elementary and Secondary 

September, 1969, 

pages 45-47. 

17. Publication, North Carolina Public Schools, Volume 44, 

No. 5, January, 1970, page 10, 

18. Affidavit of Fred O. Munn,Jr. 

19. List of newspaper articles: 

a) Charlotte News, June 12, 1969 

b) Charlotte Observer, June 17, 1969 

¢) Charlotte Observer, June 18, 1969 

d) Charlotte Observer, June 26, 1969 

e) Charlotte Observer, July 3, 1969 

f) Charlotte Observer, July 22, 1969 

g) Charlotte News, July 22, 1969 

h) Charlotte Observer, July 23, 1969 

i) Charlotte Observer, August 6, 1969 

20. 1970 edition, The World Almanac. 

21. Excerpts from Population Projection for North Carolina 

Counties, published in January, 1964. 

22. Pxcerpts from Profile, 

lished in December, 1968. 

23. Report showing number of vehicles 

for 1968 as follows: 

Automobiles 

Trucks 

161,678 

29,487 

24. Report showing number of vehicles 

~3 

North Carolina Counties, pub 

in Mecklenburg County 

in the City of Charlotf 

i   ~ 

 



  

  25. Biennial report of 

    

68 as follows: 

Automobiles 148,475 

Trucks 26,870 

Pons 

the State Superintendent of Public 

Instruction for 1966-68. 

Respectfully submitted, 

LF /l ( / : 
COL AL a. 

    

coNRAD O. PEARSON 
203 1/2 East Chapel Hill Street 

Durham, North Carolina 

CHAMBERS, STEIN, FERGUSON & LANNING 

216 West Tenth Street 

Charlotte, North Carolina 

JACK GREENBERG 

JAMES M. NABRIT, IIX 

NORMAN CHACHKIN 

10 Columbus Circle 

New York, New York 10019 

Attorneys for Plaintiffs 

  

 



  

CERTIFICATE OF SERVICE     

The undersigned hereby certifies that he has this day   
served copies of the Foregoing Plaintiffs' List of Additional 

Exhibits and Proposed Evidence upon counsel for the defendants 

and counsel for additional parties-defendant by depositing copies 

of same in the United States mail, postage prepaid, addressed to: 

Brock Barkley, Esq. 

Law Building 

Charlotte, North Carolina 

William J. Waggoner, Esd. 

Weinstein, Waggoner, Sturges and Odom 

1100 Barringer Office Tower 

Charlotte, North Carolina 

Gaston H. Gage, Esq. 

Grier, Parker, Poe, Thompson, 

| Bernstein, Gage and Preston 

1014 Law Building 

Charlotte, North Carolina 

Honorable Robert Morgan 

Attorney General 

State of North Carolina 

Raleigh, North Carolina 

James H. Carson, Jr., EBEsd. 

Law Building | 

Charlotte, North Carolina 

Benjamin S. Horack, Esg. 

806 East Trade Street 

Charlotte, North Carolina   
Whiteford S. Blakeney, Esq. 

North Carolina National Bank Building 

Charlotte, North Carolina 

and 

William A. Booe, Esd. 

Law Building | 

Charlotte, North Carolina | 

{ 

This & rf day of March, 1970.       
      : / 4 a gt . i “{ i A fs po wi ag rn, TER 

Jn rney for Plaintiff 
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