Letter from Dimond to Chackin RE Redraft Changes

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Impact area
- Education
Topic
- School Desegregation
Matter
- Milliken v. Bradley
Case
- Milliken v. Bradley
U.S. state
- Michigan
Collection
- Case Files
Taxonomy
Identifier
- 9e04aaf5-53e9-ef11-a730-7c1e5247dfc0

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Case Files, Milliken Hardbacks. Letter from Dimond to Chackin RE Redraft Changes, 1973. 9e04aaf5-53e9-ef11-a730-7c1e5247dfc0. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/8a7c2002-dd50-4f08-9e8c-86018e760ac6/letter-from-dimond-to-chackin-re-redraft-changes. Accessed November 23, 2025.

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    O'BRIEN, MORAN & DIMOND
ATTORNEYS AND COUNSELLORS AT LAW 

210 EAST HURON STREET 
ANN ARBOR, MICHIGAN 48108 

(313) 769-6838
THOMAS C. O'BRIEN 
MICHAEL C. MORAN 
PAUL R. DIMOND

October 11, 1973

Mr. Norman J. Chachkin 
l'0~^€oXumbus Circle 
New York, N . Y .. 10019
Dear Norman,

Please find enclosed my redraft of your redraft. 
These changes are made, pursuant to our conversation in 
light of a draft which places the "argument" on "racial 
balance" and analysis of Bfftmson in the argument section 
on reasons for denying certiorari. Similarly, the section 
on "the practicalities of the local situation" will be 
moved to argument. Thus the brief will move from the 
point of this redraft directly to (1) a section stating 
what has happened on remedy (i.e., no plan) and (2) the 
status of suburban districts and the remand.

In the argument, 1 suggest inclusion of a brief 
statement in the first section (on how the case is not in 
a posture for review) of how the racial balance issue 
is not ripe because no plan has been approved. In the 
second section of argument we should then include several 
paragraphs arguing (1) racial balance and Bcrunson issues 
and (2) the practicalities of the local situation to show 
how the Petitioners' questions of adequacy of Detroit only 
and impropriety of metro simply are not raised by the 
record. (See p. 33 for a very brief statement of this 
theory to be expanded by argument).

The concluding section then remains an argument on 
how the only possible question presented (as reframed by you) 
is not worthy of certiorari. (pp. 34-40 of original draft).

All the above and enclosed are suggestions.

Paul R. Dimond
mjh 
e n d .

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Letter from Dimond to Chackin RE Redraft Changes

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