Supplemental Exhibit

     [||90dbcb58-8f4f-4102-b0a3-5315ae9d63c6||] IN THE 

UNITED STATES DISTRICT COURT 

FOR THE 

WESTERN DISTRICT OF NORTH CAROLINA 

CHARLOTTE DIVISION 

  

JAMES FE. SWANN, et al., 

Plaintiffs, 

Vv. 

CHARLOTTE-MECKLENBURG BOARD OF 

EDUCATION, et al., Civil Action 
No. 1974 

Defendants, 

and 

MRS. ROBERT LEE MOORE, et al., 

Additional Parties- 

Defendant. 

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SUPPLEMENTAL EXHIBIT 

Plaintiffs fedperEially submit the attached exhibit 

captioned ESTIMATED DISTANCE AND TRAVEL TIME BETWEEN CLUSTERED 

SCHOOLS. It shows travel time and distance between the schools 

ordered to be clustered based upon figures and estimates of the 

school board. 

We submit that these figures as to distance and time 

between the schools are highly relevant. Dr. Finger testified 

that the plan he and the school staff developed anticipated that 

in the clustered schools the students would walk to their former 

schools (some would be transported) and then be directly 

transported to the distant schools. The local Board obviously 

anticipates that the plan will be implemented in this manner. 

“An examination of the data submitted on March 17, 1970 reveals 

that more than 1,000 white students will continue to be trans- 

ported to their present schools before being transported to the 

  

 



  
    

to the inner City Schools. In fact, there are approximately 25 

buses which are, and will continue to be parked at white 

schools which are to be clustered. (These buses are not planned 

to. be utilized for cross-busing.) “This exhibit vividly 

demonstrates that the defendants' assertions as to the time, 

distance, number of buses and expense involved in the cross- 

busing, which have been echoed without question by many others 

including the State Superintendent of Public Instruction, the 

Governor, local and national press and the Secretary of Health, 

Education and Welfare, are grossly exaggerated. Over one half of 

the bus trips in the system today take a longer time than the 

average trip as calculated on the attached exhibit. In the 

present system the average distance travelled is approximately 

three and one half times the projected average distance to be 

travelled by the buses serving the clustered schools. The 

average distance to be travelled as projected is less than one- 

half the average distance travelled by the buses now being 

operated on their first trip. Approximately 75% of the buses 

being operated today make more than one trip. No bus under ‘the 

Board's projected figures is scheduled to make more than one trip. 

Respectfully submitted, 

   hol CA AT 
  

CONRAD O. PEARSON 

203 1/2 East Chapel Hill Street 

Durham, North Carolina 

CHAMBERS, STEIN, FERGUSON & LANNING 

216 West Tenth Street 
Charlotte, North Carolina 

JACK GREENBERG 

JAMES M. NABRIT, 111 

NORMAN CHACHKIN 

10 Columbus Circle 
New York, New York 10019 

Attorneys for Plaintiffs 

  

 



      

CERTIFICATE OF SERVICE 

The undersigned hereby certifies that he has this day 

served copies of the foregoing Supplemental Exhibit upon counsel 

for the defendants and counsel for additional parties-defendant 

by depositing copies of same in the United States mail, postage 

prepaid, addressed to: 

Brock Barkley, Esq. 
Law Building 
Charlotte, North Carolina 

William J. Waggoner, Esq. 
Weinstein, Waggoner, Sturges and Odom 
1100 Barringer Office Tower 
Charlotte, North Carolina 

Gaston H. Gage, Esd. 
Grier, Parker, Poe, Thompson, 
Bernstein, Gage and Preston 
1014 Law Building 
Charlotte, North Carolina 

Honorable Robert Morgan 

Attorney General 
State of North Carolina 
Raleigh, North Carolina 

James H. Carson, Jr., Esdg. 

Law Building 
Charlotte, North Carolina 

Benjamin S. Horack, Esq. 

806 East Trade Street 

Charlotte, North Carolina 

Whiteford S. Blakeney, Esq. 
North Carolina National Bank Building 

Charlotte, North Carolina 

William A. Booe, Esq. 
Law Building 
Charlotte, North Carolina 

This 20/ day Of Maxch, 1970. 

~ 

on C 

[6 3 , 
  

Attorney for Plaintiff 

  

 



1/ 
ESTIMATED DISTANCE AND TRAVEL TIME BETWEEN CLUSTERED SCHOOLS ~— 
  

  

  

  

  

  

SCHOOLS DISTANCE NUMBER OE TRAVEL TIME 

TRIPS 4/ 

fa) (er) fm feb) ter) ££ Ler) a) £4) £) 
White Black Inches on Map Miles 2 5¢/ of Miles Total 2 Ba Tine 5/ Total Tim 

3 4010 3 | — shook Ei 
(a9 Db) (1L"=4000"') | (as? Db) (c X 580 Miles by Distance 12 MPH in 

(25% x 4) Road Traveled in Minutes + Minutes 

(d + e) [€£ 3» h) (f 3 5) {his 1) 

juntingtowne : 

Farms 9 5/8 73 1.8 9.1 72.8 8 (4/4) 45.5 360 

Sharon Bruns 8 7/8 6.7 7.7 8.4 33.6 4(2/2) 42 v 168" 
Avenue : 

Starmount 9 1/8 6.9 ny Ty 8.6 .:{oa.c 11(5/6) 43 473 » 

Park Road 3 1/8 2.4 «® 3.0 21.0 7114/3) 15 105 

Marie 
Pinewood Davis 31/2 2.7 7. 3.4 44.2 13(7/6) 17 221                       
1/ The figures contained in the chart are as supplied by the defendants. Plaintiffs contend that the estimate as to the number 

of children to be transported, the number of buses required and the factor (column "e") added to determine distance to be 

highly inflated. Plaintiffs further contend that the average speed of the buses (12 MPH) is grossly underestimated. 

2/ Map is Item 6a of Defendants' Submission of March 16, 1970. 

3/ Mr. J. D. Morgan testified in deposition on March 18, 1970, that an accurate estimate for the distance for a bus trip RB 
between schools can be determined by measuring the distance on the map, point to point, and adding 25%. 

4/ The information is contained in Defendants' Submission of March 17, 1970. The number of trips equals the number of buses, 

because each bus is scheduled to make only one trip. The number of buses projected for transporting black students and the 

total number of buses from the white schools to the black schools are given. The latter figure 1s apportioned between the 

white schools based upon the number of buses projected for the black students and is the second figure within the parenthesis. 

The total number of buses projected for each cluster is as given in the Defendants' Submission. 

5/ Mr. J. D. Morgan testified in deposition on March .18, 1970 that the estimated average speed for the all new buses transported 

under the order to be 12 MPH. If the buses average 20 MPH rather than 12 MPH, the average travel time would be reduced to 20.2 

minutes. 
  

 



ESTIMATED DISTANCE AND TRAVEL TIME BETWEEN CLUSTERED SCHOOLS 
  

  

  : ’ fo A) Corth fone fami 

ee SN = th) fo) a 
  

  

  

  

    

Briarwood 5.1/2 4.2 1.1 5.3 58.3 11(5.6) 26.5 231.5 

Double : 

Devonshire Oaks 7 5.3 1.3 6.6 79.2 12 (6/6) 33 396 

Hidden Druid 

Valley Hills 3 7/8 2.9 «7 3.6 43.2 12 (6/6) 18 2.6 

Beverly | 

Woods 71/2 ; 5.7 1.4 751 71 10(5/5) 35.5 355 

Lansdowne First 8 3/4 6.6 1.7 8.3 01.3 11(6/5) 41.5 456.5 

ward 

Olde : : 

Providence 11 | 8.3 : 251 10.4 52 5({3/2) 52 260 

Albemarle 

Road 10:1/4 7.7 .S 9.6 76.8 8(4/4) 48 384 

Idlewild Lincoln 10 7.5 1.9 9.5 57 5(3/3):4] 47.5 285 

Hleights ) 

Merry Oaks 5 3/4 4.4 1.1 5.5 22 4{2/2) 27.5 110 

Allenbrook : 5 3.8 1.0 4.8 33.6 7(4/3) g4 168 pL 

Paw Creek 8 6.1 1.5 7.6 53.2 7(4/3) 38 266 

Oak lawn : 

Paw Creek 

Annex : 7 7/8 6.0 wr adies 7.5 15 2(1/1) 37.5 75 

Tuckaseegee 7 “5.3 1.3 6.6 39.6 | 6(4/2) 33 198           
              
 



ESTIMATED DISTANCE AND TRAVEL TIME BETWEEN CLUSTERED SCHOOLS 
  

  

  
  

  

  

  
  

- (i) fey (3) fo) LE) fer) (hh) hs (5) — 

Hickory Grove [Tryon 8 1/8 6.2 1.6 7.8 78 10(4/6)] | 39 390 
Hills : ! 

Montclaire 10 1/8 757 1.9 9.6 96 10(4/6) 48 480 
Univern- = 

Rama Road sity 10 5/8 8.1 2.0. 10.1 111.11 {11({5/6 50.5 588.5 

| Park 

Selwyn 6 1/2 4.9 L.2 6.1 54.9 9(4/5) 30.5 274.5 A 

Windsor Park [Villa || 4 1/4 3.2 ro 4.0 40 10(5/5%1 1 20 200 
Heights 

Winterfield 4 3/8 3.2 .8 4.0 36 9(4/5)1 | 20 180 

13744) | 203 (1) 6812 (m) 

Average {Distance Per Trip|in Miles (k/1)= 
6.8 Miles 

Average |Time Per Trip in Minutes (m/1)= 
33.6 Minutes 

* [||90dbcb58-8f4f-4102-b0a3-5315ae9d63c6||]