Copy of Motion to Join and Substitute Parties, Memo in Support, and Motion to Require Submission of Proposals and Memo in Support

    UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION

)RONALD BRADLEY, et al., )
)Plaintiffs, )
)vs. )
)WILLIAM G. MILLIKEN, )
)Defendants, )
)and )
)DENISE MAGDOWSKI, )
)Defendants-Intervenors, )
)and , )
)ALLEN PARK, et al., )
)Defendants-Intervenors, )
)and )
)KERRY GREEN, et al., )
),Defendants-Intervenors, )
)and , )
)WAYNE COUNTY INTERMEDIATE )

SCHOOL DISTRICT, et al., )
' * )Added Defendants. )

______ ________________________________ __ )

CIVIL ACTION 
NO. 35257

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF 
~MOTION TO REQUIRE SUBMISSION OF 

“PROPOSALS TO LEGISLATURE

1. Bradley v. Milliken, F.2d
(Nos. 72-1809 - 72-1814, June 12, 1973 , eri banc) Slip.
Op. at 71.

PAUL R. DIMOND 
906 Rose Avenue 
Ann Arbor, Mich.

Respectful /r
48104

7 * i

,ed,

LOUIS R. LUCAS 
WILLIAM E . CALDWELL

J. HAROLD FLANNERY ’Larsen Hall 
14 Appian Way 
Cambridge, Mass. 02138

JACK GREENBERG 
NORMAN CHACHKIN 
10 Columbus Circle 
New York, New York 10019

525 Commerce Title 
Memphis, Tennessee

NATHANIEL JONES 
1790 Broadway 
New York, New York

Building
38103

10019



UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION

~ )
RONALD BRADLEY, et al,, )

)Plaintiffs/ )
)vs. )
)WILLIAM G. MILLIKEN, )
)Defendants, )
)and )
)DENISE MAGDOWSKI, )
)Defendants-Intervenors, )
)and )
)ALLEN PARK, et al., )
)Defendants-Intervenors, )
)and )
)KERRY GREEN, et al., )
>Defendants-Intervenors, )
)and )

" ' )WAYNE COUNTY INTERMEDIATE )
SCHOOL DISTRICT, et al., )

) “Added Defendants. )
)

CIVIL ACTION 
NO. 35257

MOTION TO JOIN AND SUBSTITUTE PARTIES

NOW COME plaintiffs, Ronald Bradley, et al., 
and move this Honorable Court to join the following school 
districts, the boards of and members of the boards of 
education of such school districts, and their superin­
tendents as parties in this cause in the first instance 
for hearings on metropolitan relief and as necessary to 
further planning and thereafter, insofar as necessary, in 
implementing an effective plan for desegregation of the 
Detroit Public Schools:

(a) The Wayne County Intermediate School 
District, the Oakland County Intermediate 
School District, Lakeview Public Schools,



Fitzgerald Public Schools, Fraser Public 
Schools, Harper Woods School District, Van 
Dyke Public Schools, Hamtramck School District, 
School District of the City of Troy, Highland 
Park City School District, School District of 
The City of Birmingham, Bloomfield Hills School 
District, Farmington Public School District, 
Clarenceville School District, West Bloomfield 
School District, Livonia Public School District, 
South Redford School District, Romulus Town­
ship School District, Inster School District, 
Westwood Community School District, Ecorse

i

Public School District, Southgate Community 
School District, Riverview Community School 
District, Holly Area Schools, Huron Valley 
Schools, Lake Orion Community School District, 
Rochester Community School,, Walled Lake Conso­
lidated School District, Avondale School Dis­
trict, Clarkston Community Schools, South Lyon 
Community Schools, Waterford School District,
Mt. Clemens Community School District, Anchor 
Bay School District, Romeo Community Schools, 
Clintondale Community Schools, L'anse Creuse 
Public Schools, South Lake Schools, Utica Com­
munity Schools, Armada Area Schools, New Haven 
Community Schools, Plymouth Community Schools 
District, Huron School District, Northville 
Public Schools District, Van Buren Public 
School District, Grosse lie Township School 
District, Trenton Public School District;

% *
*

(b) All other school districts, if any, in 
the tri-county area not already parties de­
fendant, with the exception of the Pontiac 
District which is already subject to the juris­
diction of another Federal District Court.

2



(c) The Boards of Education and Members of 
the Boards of Education in each school district 
in the tri-county area;

(d) The Superintendents of each school dis­
trict in the tri-county area.
Plaintiffs further move this Honorable Court 

to substitute the following as parties defendant in this 
cause:

1. Charles Wolfe for Norman Drackler as 
Superintendent of the Detroit Public Schools.

2. The present members of the Detroit Board
$

of Education for their predecessors.
Plaintiffs move that the Court order service

to be made by the United States Marshall without pay­
ment of service costs.. The joinder of these parties 
is moved by the plaintiffs in accordance with the di­
rections of the Court of Appeals and the motion is made
pursuant to Rules 19 and 21 FRCP. Rule 21 permits join­
der on the motion and order of the Court.

Respectfully submitted,

PAUL R. DIMOND 
906 Rose Avenue Ann Arbor, Mich.

J. HAROLD FLANNERY

RATNER, SUGARMON & LUCAS 
525 Commerce Title Building 
Memphis, Tennessee 38103

Center for Law and 
Education 

Larsen Hall 
14 Appian Way 
Cambridge, Mass. 02138

NATHANIEL JONES 
1790 Broadway,
New York, New York 10019

JACK GREENBERG 
NORMAN J. CHACHKIN 
10 Columbus Circle 
New York, New York 10019



UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION

5
RONALD BRADLEY, et al., )

)Plaintiffs, )
)vs. )
)WILLIAM G. MILLIKEN, )
)Defendants, )
)and )
)DENISE MAGDOWSKI, )) CIVIL ACTION

Defendants-Intervenors, )
) NO. 35257

and )
)ALLEN PARK, et al., )
)Defendants-Intervenors, )
)and )
> , .KERRY GREEN, et al., )
)Defendants-Intervenors, )
)and ' )
)WAYNE COUNTY INTERMEDIATE ' )

SCHOOL DISTRICT, et al., f
)Added Defendants. )
)

MEMORANDUM OF POINTS AND AUTHORITIES 
IN SUPPORT OF MOTION TO JOIN PARTIES

1. Bradley v. Milliken, _____ F.2d _____,
(Nos. 72-1809 - 72-1814, June 12, 1973, en banc) Slip 
op. at 71.

2. Rules 19 and 21, F.R.C.P.

PAUL R. DIMOND 
906 Rose Avenue 
Ann Arbor, Mich.
J. HAROLD FLANNERY 
Larsen Hall 
14 Appian Way 
Cambridge, Mass.
JACK GREENBERG, NORMAN CHACHKIN
10 Columbus Circle
New York, New York 10019

Respectfully submitted,

LOUISjR. LUCAS 
WILLIAM E. CALDWELL 

48104 525 Commerce Title Building
Memphis, Tennessee 38103

02138
NATHANIEL JONES 
1790 Broadway 
New York, New York 10019



CERTIFICATE OF SERVICE

This is to certify that a copy of the fore­
going Motion to Join and Substitute Parties and Memo­
randum in support thereof and Motion to Require Sub­
mission of Proposals to Legislature and Memorandum in 
support thereof have been served upon all counsel of 
record by mailing same to them at their offices by
United States Mail, postage prepaid, this ;£___  day of
August______ , 1973.

LOUIS R. LUCAS -