Answer to Amended Complaint with Cover Letter

    UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION

RONALD BRADLEY, et al.,

Plaintiffs

vs •

WILLIAM G, MILLIKEN,

Defendants,
ana

DENISE MAGDCWSKI,

Defend ants-Intervenor3,

and

ALLEN PARK, et al.,

Def emdants-intervenors,

ana

KERRY GREEN, at al.,

Defendants-Interven®rs,

and

WAYNE COUNTY INTERMEDIATE 
SCHOOL DISTRICT, et al.,

Added Defendants*

CIVIL ACTION

NO* 3525?

ANSWER TO AMENDED COMPLAINT

N ot carries the Defendant, School District *f the City »f Haiatramck, 

a Municipal C@rp®rati©n, by its Attorney Charles ¥ # Ketulski and answers the

amended complaint filed in the above entitled cause as fallows:

I* Friar Proceedings

1. Answering Paragraph One «f said amended complaint, said 

Defendant admits the recurrence ©f the prior proceedings alleged therein; 

but further states the truth t© be that the prior proceedings sheuld not be. 

applicable t© said Defendant, the Hamtramck School District,



2. Answering Paragraph ?w®, Defendant admits the allegations

therein contained, relative t» jurisdiction and further admits the amount 

exists in excess of $1,000.00*

3* Answering Paragraph Three, Defendant admits the obligati©n 

therein contained and further answering this paragraph as ts the allegation 

incorporating by reference paragraphs tna through twenty-three of the 

©riginal complaint. Said Defendant states that each paragraph contained 

should not be applicable to the School District ®f the City of Hamtramck.

II. DEFENDANTS

iw Answering Paragraph Four, said Defendant admits the 

allegations therein c@nts.iaed*

5* Answering Paragraph Five, said Defendant admits the 

allegations therein contained.

6. Answering Paragraph Six, said Defendant admits the 

allegations therein contained.

7* Answering Paragraph Severn, said Defendant admits the 

allegations therein contained.

8. Answering Paragraph Eight, said Defendant admits the 

allegations therein contained.

9 * Answering Paragraph Nine, said Defendant admits the 

allegations therein contained.

III. ADDITIONAL ALLEGATIONS TO CONFORM TO THE EVIDENCE

10* Answering Paragraph Ten, said Defendant neither admits 

nor denies the allegations therein contained for want ®f knowledge of 

same but further answers this paragraph by stating that the allegations 

suggesting patterns of segregation of black and white students in the 

Hamtramck School District is not now er never has been practiced in the 

School District of the City ©f Hamtramck by virtue of the physical 

arrangement of its Public Schools which consist of only one High School, 

one Middle School and two Elementary Schools, all of which are being 

attended by bath black and white students.

-  2 -



>

11. Answering Paragraph Eleven, said Defendant admits the 

allegations therein contained but further answers this paragraph by- 

stating that there is no need for elimination ©f segregation in the 

School District of the City af Hamtramck, said Defendant District already 

has a well balanced integrated school system,

12. Answering Paragraph Twelve, said Defendant neither admits 

nor denies the allegations therein contained far want of knowledge of 

matters existing in the Dtroit Metropolitan Area,

13. Answering Paragraph Thirteen, said Defendant neither admits 
nor denies the allegations but leave Plaintiffs to their proofs • Further 

answering this paragraph, item3 (a) and (b) Defendant denies the alleged 

conclusions therein and states that the manner in which the Hamtramck 

School District is being administered in n® way would add ®r contribute 

to any further desegregation alleged to exist within the Detroit 'School 

System*

lU* Answering Paragraph Fourteen, said Defendant denies, that the 

submitted plan for meaningful desegregation would be accomplished, by cross- 

district bussing insofar as it would apply to the School District ©f the 

City af Hamtramck.

15. Answering Paragraph Fifteen, said Defendant denies the 

allegations therein contained*

l6* Answering Paragraph Sixteen, said Defendant neither admits 

nor denies the allegations therein contained but leaves Plaintiffs to 

their prssfs,

17. Answering Paragraph Seventeen, said Defendant admits the :• , • ' ' \ 

allegations therein contained but further states that the said finding

of fact and additional allegations should not- be applicable to the Defendant,

School District af the City of Hamtramck*

Wherefore, Defendant, School District of the City ©f Hamtramck, 

asks the Court to deny the relief prayed for in Plaintiffs’ amended complaint 

and that the cause be dismissed as to this Defendant*

Charles W. Kotulski, Attorney 1 
Defendant, School District of City 
of Hamtramck 
11578 St. Aubia Avenue 
Hamtramck, Michigan 
Phone: 369-920)}.



October 25, 1973

United States District Court Clerk 
133 Federal Building 
Detroit, Michigan 48226
RE: RONALD BRADLEY, Et Al

VS. WILLIAM G. MILLIKEN, Et Al 
C. A. NO. 35257

Dear Sir:
Please find enclosed herewith Answer of Plymouth Community 
School District, The Board of Education, Members of the 
Board of Education and the Superintendent to Amended Complaint 
to be filed in the above action.

Very truly yours,
SEMPLINER, THOMAS AND GUTH

WJG/jb
enc.
cc: Mr. Paul R. Dimond Louis R. Lucas

906 Rose Avenue 525 Commerce Title Bldg.
Ann Arbor, Mi. 48104 Memphis, Tenn. 38103
J. Harold Flannery .
Center for Law & Education 
Larsen Hall 
14 Appian Way 
Cambridge, Mass 02138
Jack Greenberg 
Norman J. Chachkin 
10 Columbus Circle 
New York, N.Y. 10019

Nathaniel Jones1790 Broadway
New York, N.Y. 10019
Elliott Hall
950 Guardian Bldg.
Detroit, Michigan 48226