Objections of Defendants to the Metropolitan Plan Submitted by the State and by Way of an Alternative, Submission of a Metropolitan Detroit Area Integration Plan

    Lr.o.v S. C o iia n  
Deputy Attorney General

STATE OF N0CHXGAN 

DEPARTMENT OF ATTORNEY GENERA!

FRANK J. KELLEY
A T T O R N E Y  G E N E R A L

LANSING 
4 8 9 1 3

June 9, 1972

Mr, Frederick W. Johnson 
Clerk, Eastern District 
United States District Court 
133 U. S. Courthouse
Detroit, Michigan 48226 _

Re: Bradley et al v Milliken et al
Civil Action No. 35257

Dear Mr. Johnson:
Enclosed for filing please find the state defendants' response 
and brief in opposition to the motion for intervention filed 
on behalf of the Organization of School Administrators and 
Supervisors. A certificate of service is attached to each document.

Very truly yours,
FRANK J. KELLEY 
Attorney General

GFY:jk 
Enclosures

cc: Hon. Stephen J. Roth
Messrs. Louis R. Lucas 

and William E. Caldwell 
Mr. Donald F. Sugerman 
Messrs. J. Harold Flannery, 

P. R. Dimond & R. Pressman 
Messrs. Jack Greenberg & 

Norman J. Chachkin 
Mr. Nathiel R. Jones 
Mr. William M. Saxton
Mr. Robert J. Lord

Gerald F. Young 
Assistant Attorney General 
525 West Ottawa Street 
Lansing, Michigan 48913

cc: Mr. E. Winther McCroom
Bruce Miller & Lucille Watts 
Mr. Alexander B. Ritchie 
Mr. George T. Roumell, Jr. 
Mr. Theodore Sachs 
Mr. Kenneth B. McConnell 
Mr. Richard P. Condit 
Messrs. Douglas H. West & 

Robert B. Webster
1 - L



UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION

RONALD BRADLEY, 

and

et al,
Plaintiffs,

ORGANIZATION OF SCHOOL 
ADMINISTRATORS AND SUPERVISORS,

Applicant for Intervention 
as Plaintiff,

v s .

WILLIAM G. MILLIKEN, et al, Civil Action No. 35257

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

Defendant-Intervenor, 
DENISE MAGDOWSKI, et al, '

Defendants-Intervenors,
and

ALLEN PARK PUBLIC SCHOOLS, et al,

and
Defendants-Intervenors,

GROSSE POINTS SCHOOLS,

and
Defendant-Intervenor,

SOUTHFIELD PUBLIC SCHOOL,

and
Defendant-Intervenor,

SCHOOL DISTRICT OF THE CITY OF 
ROYAL OAK,

Defendant-Intervenor,
and

KERRY GREEN, et al,
Defendant-Intervenor.

____________________ ___ _______________________ /
RESPONSE OF STATE DEFENDANTS IN OPPOSITION TO 
MOTION FOR INTERVENTION AS PARTY PLAINTIFF FILED 
ON BEHALF OF ORGANIZATION OF SCHOOL ADMINISTRATORS 
AN D S UP E RVIS 0 RS . ___________ _________



Now come defendants, William G. Milliken, Governor of the 
State of Michigan, Frank J. Kelley, Attorney General of the State 
of Michigan, State Board of Education, and John W. Porter,
Superintendent of Public Instruction, sometimes referred to 
herein as state defendants', by their attorneys, Eugene Krasicky 
and Gerald F. Young, Assistant Attorneys General, and make their 
response in opposition to motion for intervention as party plaintiff 
filed on behalf of Organization of School Administrators and Supervisors, 
respectfully representing to this Court as follows:

1. State defendants admit paragraph 1 of the motion for 
intervention.

2. State defendants deny paragraphs 2, 3, 4, 5, 6 and 7 
of tiie motion for intervention.

3. State defendants admit paragraphs 8 and 9 of the motion 
for intervention and further admit that the documents referred to
in paragraph 10 of the motion for intervention are annexed to the 
motion for intervention.

4. State defendants will not, at this time, file their 
response and brief in opposition to the motion for injunctive and 
affirmative relief and motion to show cause filed by the Organization 
of School Administrators and Supervisors since the question of 
intervention has not yet been determined by this Court. State 
defendants assert that these motions are without merit and reserve 
the right to respond to them by way of a response and brief in the 
event this Court allows the intervention sought by the Organization 
of School Administrators and Supervisors.

5. The state defendants submit, as is more fully set forth 
in their brief in opposition to intervention, that the motion for



intervention as party plaintiff filed by the Organization of School 
Administrators and Supervisors fails to meet the requirements for 
intervention set forth in FR Civ P 24 and must be denied by this 
Court.

6. The state defendants have no objection to the appearance 
of the Organization of school Administrators and Supervisors in this 
cause as amicus curiae.

WHEREFORE, the state defendants respectfully request this 
Court to deny the motion for intervention as party plaintiff filed 
on behalf of the Organization of School Administrators and Supervisors.

FRANK J. KELLEY 
Attorney General
A y'.
Eugene Krasicky 
Assistant Attorney General
Gerald F. Young 
Assistant Attorney General
Attorneys for State Defendants
Business Address:
7 Story Office Building 
525 West Ottawa Street 
Lansing, Michigan 48913

Dated: June 8, 19 72