Correspondence from Lani Guinier to Terry G. Davis

    UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION

RONALD BRADLEY, et al, ■ .
Plaintiffs,

V'.
WILLIAM G. MILLIKEN, et al,

Defendants, , Civil Action
DETROIT FEDERATION OF TEACHERS, No. 35257
LOCAL #2 31, AMERICAN FEDERATION 
OF TEACHERS, AFL-CIO,

Defendant-
Intervenor

and .
DENISE MAGDOWSKI, et al,

Defendants- 
Intervenors.

_____________________  /

STATE DEFENDANTS' BRIEF IN OPPOSITION TO PLAINTIFFS' 
MOTION FOR AN ORDER REQUIRING STATE DEFENDANTS TO 
COOPERATE FULLY AND OPENLY AND FOR STATE DEFENDANTS 
TO PAY FOR THE REASONABLE COSTS OF A PLAN OF 
METROPOLITAN DESEGREGATION PREPARED BY PLAINTIFFS.

FRANK J. KELLEY 
Attorney General
Eugene Krasicky 
Patrick Kowaleski 
Assistant Attorneys General

Attorneys for State Defendants
Business Address:
7 Story Office Building 
525 West Ottawa Street 
Lansing, Michigan 48913



UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION

RONALD BRADLEY, et al,
Plain tiffs,

v .
WILLIAM G. MILLIKEN, et al,

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

Defenaant-
Intervenor

and
DENISE MAGDOWSKI, et al, '

Defendan ts- 
Intervenors.

_____________________________________ /

Civil Action 
No. 35257

STATE DEFENDANTS' BRIEF IN OPPOSITION TO PLAINTIFFS' 
MOTION FOR AN ORDER REQUIRING STATE DEFENDANTS TO 
COOPERATE FULLY AND OPENLY AND FOR STATE DEFENDANTS 
TO PAY FOR THE REASONABLE COSTS OF A PLAN OF 
METROPOLITAN DESEGREGATION PREPARED BY PLAINTIFFS.

Introduction
This Court rendered its decision containing its findings of 

fact and conclusions of law on September 27, 1971. A hearing was 
held on October 4, 1971 to "chart our course from here on in these 
proceedings." Tr. October 4, 1971, p 3. The Court opened the 
proceedings by indicating that it was going to order "the local and 
state school authorities to present desegregation plans." Tr. October 
4, 1971, p 3. The means of desegregation was left to the school 
authorities:

"I want to make it plain I have no preconceived 
notions about the solutions or remedies which will 
be required here. Of course, the primary and basic 
and fundamental responsibiliLv is that of the school 
authorities. . . . "  Tr. October 4, 1971, p 6.
"[Emphasis supplied]



The Court then asked fop: comments and counsel responded:
"MR. KRASICKY: As the Court is aware the
Department of Education is one of the twenty 
departments of the Executive Branch. It is . 
headed by the State Board of Education, one of 
the defendants here, and its chief executive 
officer is the Superintendent of Public Instructions, 
one of the Defendants here.

"In consulting with the Department, recognizing 
there would be a meeting today and certain inquiry 
would be made as to what the time might be for drawing 
up a plan, I was informed that in Los Angeles, and I was 
informed by a representative of the Department, when a 
desegregation plan was promulgated for that city school 
district that a contract was made with the Rand 
Corporation, a program was written and all information 
was fed into the computers and came out with a program 
six months later. Based upon this experience, and 
tnis is tiie best the department could do, they estimate 
that it will take six months to draw up a plan.
"I point out to the Court on Friday of last week,
October 1, under Michigan law, school districts were 
required to count their pupils. This is for the purpose 
of state aid and also for other reporting purposes. So 
it will be necessary to feed all of this information 
back in and that is going to take some time.
"The Department of Education also estimates that it 
will cost a quarter of a million dollars to oromulcrate 
such a plan and this is a very rough estimate. I asked 
them if they had toe money for it and they said, no, but 
they were hopeful of getting a grant to pay for it. They 
dian't tell me where the grant was coming from, what their 
prospects were, but they said they had hopes of obtaining 
such a grant.

"Obviously these defendants that I have described and 
not the other State defendants have the expertise and 
ability to prepare plans. It will take time. I am sure 
the plaintiffs will say six months is too long but we are 
responding to the Court in candor. It is going to take 
that long. It may even take longer. Some hope was 
expressed that the Court might give indications in this 
so-called metropolitan plan as to what the boundaries of 
the metropolitan plan would be. I informed them that I 
would bring it to the Court's attention.
Summing up, it will take at least six months to draw up 
a rational, understandable plan, based upon experience of 
other areas in the country. I so inform toe Court.
THE COURT: Let me stop you. As I understand it you
and toe board would like to know what I consider toe 
proper dimensions of the so-called metropolitan plan?

2 -



,:Mk . KkaSICKY: This is what 1 was asked to make
inquiry of.
"MR. 3USHNELL: Yes.
"THE COURT: I would defer to the Board on that.
"MR. KRASICKY: I shall so inform them.
"THE COURT: That is their problem and I am looking
to them for advice on that very thing. Now the 
thought I had about this matter was this, whether 
it would be proper and feasible to say to the State 
Board, 'Present to the Court a skeletal plan so 
that we can recognize the dimensions of our problem.'
It seems to me that is the first order of business 
in trying to fashion a metropolitan plan. You have 
to define the boundaries and the borders.
"Now it may be— I'm not an educator— I never aspired 
to become one, maybe I am being forced into it but 
it may be that that can't be done, I don't know.
Maybe until you come up with an overall plan you really 
can't tell me what the boundaries of it should be or 
what its dimensions should be, I don't know.
"In my simplistic approach I thought that that would 
be the starting point. If you could on the basis of 
much less than complete knowledge, which a computer 
can devour, settle on a fairly comprehensive outline 
of the territory to be covered. . . ."
Tr. October 4, 1371, pp 11, 12, 13.

Counsel for plaintiffs responded, in pertinent part:
"It may be what can be done at the present time is 
relatively limited but there are some things I am 
sure in a good faith effort that could be done. We 
also suggested that the Detroit Board and the State 
Board either jointly or separately come forward with 
their proposals for an outline of how far out we 
should go - a general proposal. I am not talking 
about assigning every child to every"'school for the 
forthcoming school year but some skeleton outline as 
the Court has suggested. In doing that I think we 
are all nounci to use the Swann remedies. As the 
court indicated there they are determining there was 
a right and we must consider, and I think the parties, 
all of us should be directed to consider all of the 
techniques ' that Swann suggests and any other technique 
which would provide a similar result.
"It may have taken six months in Los Angeles, your Honor, 
to assign every pupil to a school but certainly it 
shouldn't take more than a couple weeks to come in here 
with a reasonably informed judgment as to the .perimeters 
of the relief. I think the Court should set down a 
fairly rigid schedule and fairly quick one to come in 
to get the issue properly before the Court."
[Emphasis supplied] Tr. October 4, 1971, pp 20, 21

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After the Court had heard all counsel, the Court said:
"THE COURT: Within thirty days the Detroit
Board of Education should submit to the Court 
a concise report of progress on the Magnet Plan, 
and along with it an evaluation of its worth in 
helping to bring about a better and higher quality 
of education. Copies of both the report and also 
the evaluation shall be made available to the other 
parties litigant at the same time.
"Such other parties may have ten additional days in 
which to submit their views and evaluations of the 
progress under the Magnet Plan.
"It is further ordered that the Detroit Board of 
Education submit its plan for desegregation of its 
schools within sixty days.
"It is ordered that the State defendants submit a 
metropolitan plan of desegregation, perhaps in more 
or less skeletal form, within one hunarea twenty 
(120) days.

"Objections to each plan-, city and metropolitan, may 
be filed by the other parties litigant not later than 
thirty days after the expiration of the time set.
Such objections may be accompanied by alternate plans." 
Tr. October 4, 1971, pp 26, 27 [Emphasis supplied]

Court expected the State Board of Education, as the state party with 
primary basic and fundamental responsibility in this field to submit
plans on behalf of the State. It is equally clear that these plans
were to be skeletal only and were not to include pupil assignments.

While all counsel orally agreed that the oral decision of 
the Court need not be reduced to writing, thereafter the defendant 
State Board of Education insisted that the decision of the Court be 
put in writing. Because the plaintiffs would not approve the form of an 
order proposed by state defendants, the Court prepared and entered its own 
order dated November 5, 1971. •

On February 4, 1972 the defendant State Board of Education 
submitted 6 plans for consideration by this Court. They were submitted 
without recommendation of the State Board of Education because it was 
unable to agree on any plan or plans. See Exhibit M 9, hearings on 
Metropolitan Plan.

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Thus, tiie defendant State Board of Education, as the 
state authority with the primary, basic and fundamental responsibility 
in this field, has complied fully with the Court's direction. 
Regardless of this, the plaintiffs are seeking to alter that portion 
of the Court's decision requiring plaintiffs, if they disapprove of 
defendants' plans, to provide their own alternate plans and are 
seeking, in effect, to, require the state defendants to pay for 
alternate plans for them. Plaintiffs''requests are based on the 
conclusion that an order of this Court has not been met.

In light of tne decision of the Court of Appeal!'*"that the
District Court's action of November 5, 1971 did not constitute a
mandatory injunction pursuant to 28 USC § 1292(a), there is a question
of whether or not the Court even issued an order. As was said in
Taylor v Board of Education of New Rochelle, 288 F2d 600, 604 (1961):

". . . It is common practice for an equity judge 
first to reach a conclusion as to liability and to 
determine the aoorooriate relief later in the event 
of an affirmative finding. If the District Judge 
had said in his opinion only that a further hearing 
would be held at which the parties would have an 
opportunity to express themselves as to relief, by 
testimony, argument, or both, it would be entirely 
plain that he had not granted a mandatory injunction, 
and this would be so even if he had also stated that, 
in the interest of orderly procedure, he would expect 
the defendants to take the lead at the hearing. In 
substance this is what Judge Kaufman did. Although 
the penultimate paragraph of his opinion is headed 
'The Decree,' the context makes clear that the few 
sentences that follow were not, themselves, decretal, 
but simply explained how he planned to fashion his 
decree. To be sure, the opinion used the word 'ordered' 
with respect to the filing of a plan, just as courts 
often 'order' or 'direct' parties to file briefs, 
findings and other papers. Normally this does not mean 
that tne court will hold in contempt a party that does 
not do this, but rather that if he fails to file by the 
date specified, the court may refuse to receive his 
submission later and may proceed without it. . .

The state defendants filed an appeal from the decision of
this Court, dated November 5, 1971. Plaintiffs moved to dismiss,
relying inter alia upon the argument that upon submission of the
plans to the Court, the state defendants' claim would be moot. See
discussion under 3 below. In dismissing state defendants' appeal the

[1] BradleY v * Milliken, Appeal Dismissed, Feb. 23, 1972,
F2d (1972).

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Court of Appeals for the Sixth Circuit determined that this Court's
order was neither a final order nor an interlocutory mandatory 
injunction which could be appealed under Title 28 USC § 1292(a).

Assuming, arguendo, however, that the Court's decree of 
November 5, 1971 constituted a binding order, several things are 
clear:

1. The defendant State Board of Education's 
plan was to be skeletal only.

2. The metropolitan plan was not to be subject 
to "approval" by the plaintiffs.

3. The State Board of Education, as the state 
authority with the primary, basic and 
fundamental responsibility in this area, 
has complied fully with the directive of 
November 5, 1971.

ARGUMENT
1. The plan was to be skeletal only.
It is clear from the comments of court and counsel at the 

•October 4, 1971 proceedings that the metropolitan plan to be 
submitted was to be skeletal only in that it was to define the 
boundaries and the borders of the metropolitan plan and was not 
intended to discuss such things as pupil assignments.

When asked by counsel for the state defendants whether the 
Court intended to establish the perimeters of the metropolitan plan 
tiie Court indicated it would defer to the State Board of Education 
on the matter:

"That is their problem and I am looking to them 
for advice on that very thing. Now the thought 
I had about this matter was this, whether it would 
be proper and feasible to say at the State Board,
'Present to the Court a skeletal plan so that we 
can recognize the dimensions of our problem.' It 
seems to me that is the first order of business in 
trying to fashion a metropolitan plan. You have to 
define the boundaries and the borders.

-6



"Now it may be--I 'm not an educator-:— I never - 
aspired to become one,, maybe I am being forced, 
into it but it may be that that can't be done,
I don't know. Maybe until you come up with an 
overall plan you really can't tell me what the 
boundaries of it should be or what its dimensions 
should be, I don't know. .
"In my simplistic approach I thought that that 
would be tile starting point. If you could on the 
basis of much less than complete knowledge, which 
a computer can devour, settle on a fairly compre­
hensive outline of the territory to be covered.
. . ." p. 13

Counsel for plaintiffs clearly understood that a detailed 
plan was not intended by the Court's directive. In discussing the 
State Board's role the plaintiffs questioned only the required time 
for preparation of such a plan, and not on the scope of the plan: 

[MR. LUCAS] -
"It may be what can be done at the present time 
is relatively limited but there are some things 
I am sure in a good faith effort that could be 
done. We also suggested that the Detroit Board 
and the State Board either jointly or separately 
come forward with their proposals for an outline 
of how far out we should go - a general proposal,
I am not talking about assigning every child to 
every school for the forthcoming school year but 
some skeleton outline as the Court has suggested. .
In doing that I think we are all bound to use the 
Swann remedies. As the court indicated there they 
are determining there was a right and we must 
consider, and I think the parties, all of us should 
be directed to consider all of the techniques that 
Swann suggests and any other technique which would 
provide a similar result.
"It may have taken six months in Los Angeles, your 
Honor, to assign every pupil to a school but certainly 
it shouldn't take more than a couple weeks to come 
in here with a reasonably informed judgment as to 
the perimeters of the relief. I think the Court 
should set down a fairly rigid schedule and fairly 
quick one to come in to get the issue properly before 
tne Court." pp 20, 21.

’ Thus, defendant State Board of Education, as the state 
authority with the primary, basic and fundamental responsibility in 
this field, was given 120 days in which to submit a metropolitan 
plan of skeletal nature. For plaintiffs to now take the position

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•  •I. ' I ■ .

that the-submission of detailed plans, including pupil assignments, 
was intended by the Court's directive is completely contrary to 
its October 4, 1971 position, as quoted above. Therefore its 
position is untenable. .

2. The metropolitan plan was not to be subject 
to “approval" by the plaintiffs.___________

The plaintiffs have taken the position that since the 
metropolitan plans submitted by defendant State Board of Education, 
as the state authority with the primary, basic and fundamental 
responsibility in this field, are not as detailed as they would 
wish, the Court should require state defendants to pay for experts 
hired by plaintiffs to prepare a metropolitan plan. In support of 
this position plaintiffs cite Swann v Charlotte-Mecklenberg Board 
of Education, 306 F Supp 1299 (1969), aff'd 402 US 1 (1971), and 
Jackson v School Board of Lynchburg, Civ No. 534 (WD Va, April 28, 
iry/U; . m  m e  aw aim case m e  xoeai uuani had been erdexed Lhxee 
times to submit new plans for desegregation of its schools. After 
study of its latest plan, it was clear to the Court that under the 
board’s proposal the seven black elementary schools in the system 
would remain 100% black. It was then that the Court ordered a 
desegregation plan to be prepared by an expert. In Jackson, the 
district court found that the school board's plan for desegregation 
did not comply with constitutional requirements. When the board 
indicated that it was unable to devise an alternate plan, the court 
allowed the plaintiffs to prepare a plan at the defendants' expense.

The facts in Swann and Jackson differ materially from the 
present case where there has been no suggestion that the metropolitan 
plans submitted by the defendant State Board of Education, as the 
state authority with the primary, basic and fundamental responsibility

-8



in this field, do not, at least in several of them, define the 
perimeters of the metropolitan plan or will not desegregate the 
Detroit school system. It is true that the state defendants did 
not call witnesses to support these plans since the State Board 
of Education had not been able to agree on a recommendation among 
tire plans and because defendants Milliken and Kelley had filed 
objections to the plans. Nevertheless the persons responsible for 
formulation of the plans have been made available to answer plaintiffs' 
question concerning the plan which was prepared at the request of 
the Court. Indeed plaintiff took the deposition of Dr. Lawrence 
Hillman, co-author of the Metropolitan School District Reorganization 
Plan and said plan is the basic ingredient of the Neighborhood School 
Based Metropolitan Plan. A fair reading of such entire plans indicates 
a conclusion by their authors that, educationally speaking, the plans 
offer maximum integration of the three county Wayne, Oakland and 
Macomb area. Instead of seeking answers from Dr. Hillman and 
Mr. Mogk, his co-author, the plaintiffs have chosen to request the 
Court to require the state defendants to pay for a different plan 
contrary to the Court's directive.

The plaintiffs have objected to the plans submitted by the 
State Board of Education, as the state authority with the primary, 
basic and fundamental responsibility in this field. A plain reading of 
the Court's directive or order indicates that plaintiffs, if they so 
desired, could submit alternative plans at their own expense. To 
require the state defendants to finance plaintiffs' plan, especially 
when the State Board of Education's own skeletal plans have not been 
fully developed, was clearly notwithin the intention of the Court on 
October 4, 1971 and reduced to writing on November 5, 1971.

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authority with the primary, basic and 
fundamental responsibility in this field, 
complied fully with the directive of November 
5, 1971._______  ____

In compliance with this Court's November 5, 1971 directive, 
the defendant State Board of Education,has submitted 3 metropolitan 
■plans, which would, the state defendants believe, define the 
perimeters of the metropolitan plan and would desegregate the 
Detroit public schools. The Governor and the Attorney General have 
not prepared a desegregation plan because, as their counsel stated 
on October 4, 1971, they do not have the technical expertise for 
such an endeavor and because, as pointed out above, the Court had 
indicated that the decisions on the perimeters of the plan to be 
submitted were left to the State Board of Education. Proceedings 
of October 4, 1971, pp 12, 13.

Six plans for the desegregation of the Detroit pubV-> 1
V i - C i  t '  ~  '  J ~  ^  -«----- J - U  -  ----------x-  _ _ _  V - ---------- -----------  A 1 O n  H  m - u  ~  ^  i  ^  4  ^  4 . 4  4= -P

cite Dr. Porter's statement that the State Board "didn't make a 
decision, period," as indicating that the State Board did not submit 
any plans to the Court. A fair reading of Dr. Porter's deposition 
indicates the contrary:

[MR. DIMOND]
"Let's just hypothesize for a moment. A Judge has 
to make a decision affecting the lives of a million 
children. Now, are you saying to me as a professional 

■ educator and as the Superintendent of Public Instruction
in the State of Michigan, you have no advice to give the 
Judge as to which is best?
[DR. PORTER]
"I have given the Judge -- the Judge has before him 
the information that I think addresses itself to 
all of the questions. The Judge also has a lot of 
other advice. I think the State Board of Education 
in receiving all of this information, has adopted a 
resolution that speaks for itself. It didn't make 
a decision, period. ■
"Q. I understand that.
"A, Okay.

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"Q. If x remember correctly, the motion says that 
these plans are to be submitted with no recommendation?
"A. That's right." p 83.

It was understood by everyone at the hearing that Dr. Porter 
was testifying that the State Board of Education made no decision

i

to recommend any one plan to the Court. All of the plans were 
submitted in a good faith attempt to meet the Court's request for 
assistance in defining the perimeters of the metropolitan plan and 
in effectively desegregating the Detroit schools.

It is also clear that the plaintiffs themselves recognized 
that the state defendants' obligations concerning the preparation of 
plans would be satisfied upon submission of State Board of Education 
plans to the Court. In opposing the state defendants' appeal of the 
Court's November 5, 1971 ruling, the plaintiffs said:

"In the instant case the Detroit Board defendants
have already submitted plans in accordance with
4 —U  v  —> v \  ^3  4— C  4 -  n  4 -< - \  p o - f  A n r i  4 - 0  r  , t  i  " 1 1  Q  n  V\TY» i  4~

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U i e i i .  p j . c u i £>  w x  u u i i  l w u  • jli i u b  f  x u i i t j  u c i u i c
briefs are filed in this appeal, the order from 
which defendants appeal will have, 'by its terms, 
expired.' • Robinson, supra, App. 1 at 3." .
Motion to Dismiss Appeals, Jan. 24, 1972, pp 10-11.

To claim now that the ruling was not complied with by the 
submission of State Board of Education plans is a contradictory 
position, formulated to suit the convenience of the plaintiffs.

Conclusion

At the time this brief is being written, the Court has before 
it at least 5 plans which propose to define the perimeters of the 
metropolitan plan and would appear to be capable of desegregating 
the Detroit Metropolitan area. These are:

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•  •

1. Intervenor Magdowski's plan for a borough 
system in the Wayne, Oakland and Macomb area.

2. The State Board of Education's Metropolitan 
School District Reorganization Plan.

3. The State Board of Education's Neighborhood 
School Based Metropolitan Plan.

4. The State Board of Education's Metropolitan 
One-Way Movement Plan.

5. The Detroit School District's Metropolitan Plan.

It appears from the four corners of each of these plans 
that each defines the perimeters of the metropolitan plan and any 
one of them could provide for the desegregation of the Detroit 
school system. Since the hearings on these plans have not been 
completed, it appears to be inappropriate at this time to consider 
tiie formulation of any new plans.

Earlier in this litigation the plaintiffs sought an order 
to require the Detroit school board to finance an intra-district plan 
which was to be prepared by plaintiffs' expert. This motion for 
costs was not pursued by the plaintiffs but the Detroit board did 
cooperate with the plaintiffs in the preparation of a plan. This 
plan was found to be constitutionally infirm:

"7. . . .  The plan would make the Detroit school
system more identifiably Black, and leave many of
its schools 75 to 90 per cent Black. . . ."
[Findings of March 28, 1972]

Thus, if the Court had ordered the school district to 
finance the plan, the expenses involved would have been unwisely 
incurred.

The arguments of the plaintiffs are advanced only to 
achieve the purpose of requiring someone else to pay for the 
plaintiffs' plans. The October 4, 1971 opinion and the November 5, 
Order do not indicate that the objectors' plans are to be paid for

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by any of the defendants, but rather are to be paid for by the 
objectors themselves. . .

they have followed the directions of, the District Court as required 
by the Court's October 4 and November 5 rulings. The school 
authorities were required to submit' a plan of desegregation which 
was to be skeletal, in that it defined the perimeters of the 
metropolitan plan, and was not to provide for pupil assignments. 
Five plans have been submitted to the Court and there has not been 
a ruling that these plans fail to meet constitutional requirements. 
Although the State Board of Education submitted these plans without 
recommendation, since they were unable to agree upon them, the con­
sultants who prepared these plans'have been made available to the 
plaintiffs for purposes of explaining the plans.

Court to deny plaintiffs' motion for an order requiring state 
defendants to cooperate fully and openly and for state defendants 
to pay for the reasonable costs of a plan of metropolitan desegre­
gation prepared by plaintiffs.

In summary, the state defendants assert affirmatively that

WHEREFORE, state defendants respectfully request the

Respectfully submitted
FRANK J. KELLEY 
Attorney General

Patrick Kowaleski
Assistant Attorneys General

Attorneys for State Defendants
Business Address:
7 Story Office Building 
525 West Ottawa Street 
Lansing, Michigan 48913

Dated: April 6, 1972

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CE RTI FI CATE OF ' SE RVICE

I hereby certify that on the 6th day of April, 1972, I
served a true copy of the foregoing State Defendants' Brief 
upon each of the following named attorneys of record, by mailing 
the same to him by first class mail, postage fully prepaid, addressed 
to his last known business address:

Messrs Louis R. Lucas 
and William E. Caldwell

Mr. Nathaniel R. Jones .
Messrs. J. Harold Flannery

Paul R. Dimona and Robert Pressman
Mr. E. Winther McCroom
Messrs. Jack Greenberg and 
Norman J. Chachkin

Mr. George T. Roumell, Jr.
Mr. Theodore Sachs
n £  . a i t J A a i i u c i  £> . f t i t u n t ;

Kenneth B. McConnell
Condit & McGarry
Ml*'. William M. Saxton
Messrs. Douglas H. West and 

Robert B . Webster
Mr. Robert J. Lord