Incomplete Statement of Time Spent, Expenses Incurred and Fees Received by Plaintiffs' Counsel

     [||dbd85691-9ee7-4673-993d-65b9a3642e6c||] » v 

E 

IN THE 

UNITED STATES DISTRICT COURT 

FOR THE ‘/ 
S$ 

WESTERN DISTRICT OF NORTH CAROLINA » 
3) 

CHARLOTTE DIVISION (7% 

  

JAMES E. SWANN, et al,, 

Plaintiffs, 
CIVIL ACTION 

Vv. NO. 1974 

THE CHARLOTTE-MECKLENBURG 

.; BOARD OF EDUCATION, et al., 

Defendants. 

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STATEMENT OF TIME SPENT, EXPENSES 

INCURRED AND FEES RECEIVED 
BY PLAINTIFFS' COUNSEL 
  

Plaintiffs, by their undersigned counsel, hereby submit 

i. a statement of time spent, expenses incurred and fees received 

by plaintiffs' counsel in support of their pending motions that 

counsel fees and litigation expenses be taxed as costs in con- 

| nection with the above-styled case. 

F T.. Introduction. 
  

This document is filed in support of plaintiffs' pre- 

| vious motions that counsel fees be taxed against the defendants 

as costs. The following sections set out in detail the amount 

of time spent, the expenses incurred and the fees received by 

plaintiffs' counsel. This section explains who the lawyers have 

been, the effect of this litigation on their practice while the 

case was in active litigation and the sources of information con- 

tained in the following section. 

Julius LeVonne Chambers has been the chief counsel for 

the plaintiffs from the time suit was filed in 1965; he continues 

to be plaintiffs' chief counsel at the present. 

  

 



  

When the suit was first filed Chambers practiced alone 

in Charlotte, North Carolina. He received some assistance with 

the case from attorneys employed by the NAACP.Legal Defense and 

| Educational Fund, Inc. in New York City during the initial trial 

f and appeal in 1965 and 1966. 

| Chambers organized the law firm of Chanbers, Stein, 

i Ferguson & Lanning at about the time the Motion for Further 

h Relief was filed in this case in September, 1968. Each of his 

| partners has worked on the case at one time or another since 

| then and has regularly consulted with him concerning the case. 

Since May, 1969, Adam Stein, a partner in the firm of 

| Chambers, Stein, Ferguson & Lanning, has actively participated 

| in all subsequent phases of the case. 

During several periods, Chambers and Stein have devoted 

almost all of their time to the case. For about six weeks in 

| March and April of 1969, Chambers worked nearly exclusively on 

i! the case. For another six weeks extending through June, July and 

¥ august of 1969, Chambers and Stein spent nearly all of their time 

with the case. From February, 1970, until the case was argued 

in the United States Supreme Court in October, 1970, Chambers and 

Stein worked on the case almost to the exclusion of all other 

matters. 

James M. Nabrit III, the associate general counsel of 

the NAACP Legal Defense and Educational Fund, Inc. of New York 

City, began assisting Chambers and Stein with the case on a nearly 

fulltime basis beginning in March, 1970. The actual work on the 

case has thus been performed by Chambers, Stein and Nabrit and, to 

a lesser extent, by other members of the Chambers, Stein,Ferguson 

& Lanning firm. However, other lawyers knowledgeable in civil 

 



rights and school desegregation litigation were consulted from 

time to time about various aspects of the case. This has included 

Jack Greenburg, the Director-Counsel of the NAACP Legal Defense 

and Educational Fund, Inc., Charles Stephen Raulston, the Assist- 

1 ant Counsel and Norman Chachkin, who supervises the Fund's school 

desegregation program. Also, during the Supreme Court phase of 

| the case, they consulted at some length with Professor Anthony 

' G. Amsterdam of the Stanford Law School, an expert in constitu- 

tional litigation. 

The following section indicates a statement of the 

amount of time spent by plaintiffs' counsel on this case. The   time assigned for each aspect of the work done represents our 

best estimate. No time sheets were kept because the fee arrange- 

ments between the Legal Defense Fund and Chambers, Stein, Ferguson 

189° Lanning are not on an hourly basis and because Nabrit is on 

. salary with the Legal Defense Fund and does not regularly maintain 

! time sheets. The estimates are based upon our review of our files, 

calendars and the bookkeeping records maintained by Chambers, Stein, 

| Ferguson & Lanning and by the Legal Defense Fund. The time shown 

| does not reflect the very many hours spent on the case consulting 

with individuals and groups in the community, in person and on 

+£hs telephone. It does not reflect the many formal and informal 

conferences among plaintiffs’ counsel. It does not reflect all cof 

the many conferences conducted by the court with counsel for all 

the parties. It is, therefore, for the most part, an estimate of 

time spent in the more formal legal matters involved with the case 

and excludes the enormous demands on the lawyers' time in less 

formal ways which were required by undertaking the representation 

of the class of black parents and students in this case.  



  

IX, Attorneys' time and feeg received.’ 
  

Date Time Spent Fee Received 
  

He 8-9, 1968 Conferences with Charles : 

Green concerning demo- : 
graphic study of Mecklen- 
burg County; collection of 
information concerning zon- 
ing, city planning, govern- 
mentally-assisted housing, 
and information concerning 
the racial distribution of 
students and teachers in the 
schools, student assignment 

plans, the kinds of programs 
and facilities at the various , | 
schools; and preparation of ! 
Motion for Further Relief : 
filed on September 8, 1968. 40 hrs. $125.00 

  

2. 9-10-68 Preparation of plaintiffs’ 
} - interrogatories 4 hrs. 

3. 10-4-68 Preparation of response to 
defendants' motion for ex- 
tension of time 1/2 hr. 

i 4, ... Preparation of plaintiffs’ 
Answer to Defendants' In-. 
terrogatories filed on : 
January 9, 1969 3 hrs. | 

5. 1-21-69 Hearing on motion by plain- 
H tiffs for an order to take 

depositions of officials and 
officers of the school board 2 hrs. 125.00 

ii6. 1-22 thru 
| 24, 1969 Conferences with Drs. Finger, 

Passey and Larsen concerning 
development of desegregation | 

proposals and analysis of the 
school system 15 hrs. 50.00 

7: 1=28 5 29, 
1969 Depositions of school beard 

employees filed on March 10, 
1969 16 hrs. 250.00 

8. 2-3-69 Preparation of interrogatories 
addressed to defendants 4 hrs. 

  

1/ The "fees received" are from the NAACP Legal Defense and 

= Educational Fund, Inc. This applies only to work done by 

Chambers, Stein, Ferguson & Lanning; James M. Nabrit III 
is a salaried employee of the Legal Defense Fund. 

 



  

Date 
  

2-20 thru 

22,1969 

2-28-69 

3-6-69 

3-7 thru 

9, 1969 

3-10-69 

3-11-69 

3~12-69 

3-13-69 

3-15 § 

16, 1969 

3-18 thru 
21,:1969 

Time Spent Fee Received 
  

Trip to New York to confer 
with educational experts 
concerning additional testi- 
mony about the effects of 
segregation, an analysis of 
the Charlotte-Mecklenburg 
school system and desegrega- 
tion proposals in preparation 
Zor trial. 11 

Preparation of plaintiffs’ 
answer to defendants' in- 
terrogatories filed on 

3-3-5659, 4 

Preparation of plaintiffs’ 
further interrogatories 
to defendants. 2 

Preparation of plaintiffs’ 
further answer to defendants’ 
interrogatories. 2 

Preparation for trial including 
conferences with Charles Green, 
Daniel Hennigan, Paul Leonard, 
Jack Larsen, John Finger and 
Robert Pasey. ut 17 

Beginning of hearing on plain- 
tiffs' Motion for Further Re- 
lief and preparation for fol- 

lowing day's hearing. 12 

Continuation of hearing and 
preparation for hearing the 
following day. 12 

1” n 9 

Continuation of hearing. 8 

Tour of the city with and con- 
ferences with City Planner, 
Yale Rabin. 10 

Case re-opened for the testi- 

mony of Yale Rabin 7 

Preparation of plaintiffs’ 

proposed findings of facts, 
conclusions of law and brief 17 

Hearing re-opened for the 

testimony of William McIntyre 7 

$100.00 

75.00 

125.00 

125,00 

125.00 

125.00 

125.00 

  

 



  

213 

22. 

23. 

ii 26. 

27 

28, 

Date 

5=15-69 

6-10-69 

6-9 thru 

12, 1969 

6-13-69 

8-16~69 

6-15-69 

6-16 thru 

18,1969 

7-18 thru 

21,1969 

Time Spent Fee Received 
  

Preparation of motion for 
temporary order restraining 
the school board from ini- 

tiating or continuing con- 
struction of new schools with- 
out prior approval of the court 
because of the failure of the 
board to comply with the pre- 
vious order of the court and the 
pendency of new construction 
plans. 4 hrs. 

Hearing on motion with respect 
to production of documents. 3 hrs. 

Preparation of plaintiffs’ 
response and objections to de- : 
fendants' desegregation plan 

as entirely inadequate and 
motion for civil contempt on the 
ground that the board had dis- 
obeyed the order of April 23, 
1969. 5 hrs. 

Conference in chambers with 

court. 3 hrs. 

Preparation of response to de- 
fendants' motions to strike 
additional parties defendant. 2 hrs. 

Preparation for hearing on 
desegregation plan. 5 hrs. 

Hearing on desegregation plan 
and motion of individual board 
members to set aside order en- 
joining them as additional de- 
fendants, including conferences 
and preparation on the evenings 
of June 16 and 17. 30 hrs. 

Preparation of motion for leave 
to file supplemental complaint, 
to add additional defendants 
and for temporary restraining 
order, and brief, and proposed 
supplemental complaint attack- 

ing as unconstitutional and 
obstructive of previous orders 
in the case of the recently en- 
acted Anti-Bussing Law. 18 hrs. 

$125.00 

125.00 

500. 

375. 

  
00 

00 

 



  

  

29. 8=4-«49 

30..:8«5 & 6, 

31. 

32+ 9=2-69 

33... 9-11-69 

34. 10-8-69 

35,.11-3~-65 

36. 11-21-69 

Time Spent Fee Received 
  

Analysis of defendants’ 
amended desegregation 
plan and report filed in 
connection therewith and 
preparation for hearing. 5 hrs. 

Hearing on amended plan. 9 hrs. $250.00 

Preparation of plaintiffs’ 
response to intervene filed 
by Paw Creek patrons. 3 hrs. 

Preparation of Motion for 
Further Relief and for an 
order directing the defendants 
to show cause why they should 

not be held in contempt for 
failing to implement the order 
of the court of August 15, 1969, 
approving the board's amended 
desegregation plan. : 3 hrs. 

Securing an order releasing 

certain of plaintiffs' exhibits 
to plaintiffs' counsel for a 
period of 30 days. ; dhe. 

Preparation of plaintiffs’ 
response and objections to 

defendants' motion for an ex- 
tension of time to file the 
desegregation plan and a re- 

quest by plaintiffs that the 
court appoint an educational 
consultant to prepare an adequate 

desegregation plan because of 
the default by the defendants in 
preparing one of their own. 3 hrs. 

Preparation of plaintiffs’ 
response and objection to 
defendant's motion for an ex- 

tension of time and motion for 
further relief. 4 ‘hrs. 

Preparation of and research for 
plaintiffs' response and ob- 
jection to defendants' amend- 

ment to plan for further desegre- 
gation of schools, claiming 
total default by the school board 
in obeying previous orders of the 
court and r juesting that the court gue 

efendants' plan, ap- 
ert to prepare a plan 

 



  

Date Time Spent Fee Received 
  

at the expense of the de- 
fendants, enjoining further 
school construction, order 
each of the defendants to show 
cause why he should not be held 
in contempt and award plaintiffs 
costs including attorney fees. 6 hrs. 

37. 1-20-70 Preparation of motion for the im- 
mediate desegregation of the pub- 
lic schools requesting that the 
Finger plan be filed promptly 
and be implemented at once in 
conformity with decisions of the 
United States Supreme Court and 
the United States Court of Ap=- : 

peals for the Fourth Circuit. 5 hrs. $125.00 

38.. 1-29 &.:30, - 
1970 Conferences in preparation 

for hearing on the Finger 
plan. 2 hrs. 

39.-2-2-70 Hearing on plaintiffs' motion 
for immediate desegregation 

and conferences with the 
court. 12 hrs.” 125.00 

i 40. 2-4-70 Preparation for hearing on 
| desegregation plans. : 7 hrs.* 

| 41. 2=-5~70 Hearing on desegregation 
plans. 6 hrs.* 200.00 

42. 2-13-70 Preparation of motion to 

add Tom B. Harris and others 
who were plaintiffs in a state 
court proceeding, their attor- 
ney, William H. Booe, and Super- 
ior Court Judge McLean who had 
entered an order on their behalf 

enjoining the school board from 
spending money to operate a 

transportation system as directed 
by this court; to add the Gover- 
nor, and the controller of the 
State Department of Public In- 
struction as defendants and be- 

. cause they had threatened to 
withhold state monies necessary 
to implement the orders of this 
court and for a motion restraining 
them and all other defendants from 
interfering with the orders of the 

  

*This represents time spent by Chambers and Stein. The additional 
work done by more than one lawyer prior to this time has not been 
stated. Hereafter, where Chambers and Stein both were involved 

with work on the case and the time of both of them is counted, 
an asterisk will appear after the number of hours shown. 

-3- 

 



  

Date 

143. 2-20-70. 

ha4, 2-24 5 25. 
| 1970 

145, 2-27-70 

146. 2-27-70 

47. 2-27-70 

48, 2-29-70 to 
3=2=70 

43, 3=) &. 32, 

530.. 3-2 & 3, 

Time Spent Fee Received 
  

court and failing to 

implement the orders of the 
court, 9:hrs.* 

Trip to Raleigh to take the 
deposition of officials of 
the State Board of Education. 7 hrs. 

Preparation for and taking of 
depositions of Morgan, Self, 
and £. D. McMillan, Jr. 12 hrs.* 

Preparation of motion to add 
as parties defendant Mrs. 
Robert Lee Moore and other 
plaintiffs in a suit brought 
in the Superior Court of 
Mecklenburg County, attorney 
Whiteford S. Blakeney and 
Superior Court Judge Frank 
Snepp, who entered an ex party 
order on Sunday evening, Febru- 
ary 22, purporting to enjoin 
the school board from putting 
into effect the prior orders of 
this court and moving that the 
state court order be set aside 

and seeking further relief from 
efforts by these persons and 
other defendants from continued 
interference with the orders 
of this court. 6: hrs. * 

Preparation of motion for tem- 
porary restraining order and 
for contempt and affidavit in 
support thereof, further seek- 
ing orders protecting the rights 
of the plaintiffs as previously 
declared by the court. 3 hrs.* 

Preparation of plaintiffs' re- 
quests for admissions. 3 hrs.* 

Preparation of proposed find- 
ings of fact, conclusions of 
law and brief with respect 
to the North Carolina Anti- 
Bussing Statute. 10 hrs. 

1" " 2 days 

(Nabrit) 

Preparation of plaintiffs' op- 
position to defendants' ap- 
plication for stay addressed 
to Judge Craven. 10 hrs. * 

$125.00 

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125.00 

125.00 

 



  

Date Time Spent Fee Received 
  

21+: 3=-3=70 Preparation of plaintiffs’ 
opposition to defendants’ 

application for stay ad- 
dressed to Judge Craven. 1 day 

(Nabrit) 

52. 3-270 Preparation of plaintiffs’ 
brief in support of their 
motion for temporary re- 
straining order and for con- 

tempt and attorneys' con- 
ference with court. 5 hrs.* 

i153. 3~4-70 Preparation of plaintiffs’ 
list of additional exhibits 
and proposed evidence. 6 hrs.* 

54. 3-6 thru Preparation of application to 
9,1970 the United States Supreme 

Court to vacate partial stay 
order entered by the Court 
of Appeals on March 5, 1970. 

: 30 hrs.* $400.00 
55« 3-4~70 3 n 3 days 

(Nabrit) 

156. 3-9-70 Preparation of notice of 
deposition of James H. Car- 
son, Dr. Finger and J. D. 
Morgan. ; l hr. 

57+.:3~11-70 Preparation of plaintiffs' 
1 response to defendants' motion 

to quash subpoena and taking 
J. D. Morgan's deposition and 
hearing. 3 hrs. 

58. 3-11-70 Taking of deposition of J. D. 
Morgan. : 3 hrs. 125.00 

59... 3-11-70 Taking of deposition of John 
A. Finger. 5 hrs.” 

60. :3~11-70 Taking of deposition of James 
H.. Carson, Jr. 2 hrs.” 

6l.: 3-12-70 Negotiation for and preparation 
of stipulations by the plain- 

‘ tiffs and State Superintendent 
of Public Instruction. 2 hrs. 

62. 3-14 thru Plaintiffs’ preparation of and 
16,1970 submission of additional data 

and exhibits and attorneys’ 
conferences with the court. 27 hrs.* 250.00 

63. Welsh i " 3 days 
(Nabrit) 

-10- 

 



  

64. 

65. 

66. 

"11 68. 

69. 

70. 

h 71. 

72. 

73. 

74. 

Date 
  

3-18-70 

3-18 & 19, 

3-22 thru 

24,1970 

3-30 thru 

1970 

3-25-70 

3-25-70 

3-27-70 

3-27 .& 
28,1970 

4-6-70 

4- 

4- 

4- 

4- 

l thru 

6-70 

7 thru 

9-70 

-8 & 

»9=70 

Time Spent Fee Received 
  

Preparation of a list of 
additional exhibits and 
hearing on defendants’ 

objections thereto. 5.hrs.* $100.00 

Preparation for and taking 
deposition of J. D. Morgan 
with respect to the school 

board's transportation 
estimates. 18 hrs.* 

Preparation of plaintiffs’ 
memorandum of additional 
points of authority for hear- 
ing on the constitutionality 
of the Anti-Bussing Statute, 
preparation for hearing and 
hearing, and attorneys' con- 
ferences with the court. 50 hrs.* 375.00 

n LE 3 days 

(Nabrit) 

Conference in chambers with 
opposing counsel, District 
Court Judge and Judge Craven.l2 hrs.* 

" " : 1 day 

(Nabrit) 

Preparation of motion in the 
Court of Appeals to strike 
defendants' appeals from all 

orders prior to February 5, 
1970. hr. 

Preparation and conferences 
concerning appendix on 
appeal. 4 hrs. 125.00 

Preparation of plaintiffs’ 
brief on appeal in the 
United States Court of 
Appeals. 110 hrs.* © 1,000.00 

" i 6 days 
(Nabrit) 

Preparation for and argument 
in the United States Court 

of Appeals in Richmond. 40 hrs.* 400.00 

" n 2 days 

(Nabrit) 

-11- 

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76. 

77. 

78. 

79. 

80. 

81. 

82. 

B83. 

84. 

85. 

86. 

B7. 

88. 

  

Time Spent Fee Received 
  

Date 

6-2 and Preparation on petition 
6~3-70 for writ of certiorari, 16 hrs. 

6-1 thru " 9 3 days 
6-3-70 I (Nabrit) 

6-8 thru n N 40 hrs. 
6-12-70 (Chambers) 

6-11 thru v n 36 hrs. 
6-15-70 (Stein) 

6-16 and B 4 16 hrs. 
6-17-70 (Stein) 

6-8 thru i n 10 days 
6-17-70 (Nabrit) 

7-6 and Preparation of plaintiffs’ 
7-77-70 response to the defendants’ 

submission pursuant to the 

order of the Court of 
Appeals. 6 hrs. 

7-8 and Preparation for and taking 
7-10-70 of deposition of John P. 

Cross and Henry L. Kemp, 

author of the HEW plan; of 
Dr. Carleton Watkins, author 
of the board minority plan; 

of William E. Poe, chairman 
Of the school board; of J. D. 
Morgan, the official respon- 
sible for bus transportation; 
and of Dr. William Self, the 
superintendent of schools. 40 hrs.* 

7-12 and Preparation of appendix for 
7-13-70 Supreme Court. 2 days 

(Nabrit) 

7-13 and Preparation for further hearing 
7-14-70 on desegregation plans. 20 hrs.* 

" " 1" 3 days 

(Nabrit) 

7-15 thru Further hearings on 
7-17-70 and desegregation plans. 72 hrs. 
7-20 thru (Chambers) 

7-24-70 20 hrs. 
(Stein) 

8 days 
(Nabrit) 

7-25 thru - Preparation of brief on 7 days 
7-31-70 the merits for United (Nabrit) 

States Supreme Court. 

5 

$125.00 

300.00 

250.00 

250.00 

50.00 

350.00 

700.00 

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89. 

90. 

91, 

92. 

93. 

i 94. 

| 95, 

i 96, 

98. 

29. 

100. 

201, 

Date 
  

7-28 thru 

7-31-70 

8-4 thru 

8-8-70 

8-11 and 
8-12-70 

8-14 and 

8-15-70 

5-21-70 

8-21 thru 

8-23-70 

8-22 and 

8-23-70 

9-8 thru 

9-10-70 

9-10 thru 
0w28=70 

9-23 thru 

9-25-70 

9«21 thru 
S=28-70 

9-30 thru 
10=4~-70 

9-30 thru 
10-2-70 

Time Spent Fee Received 
  

Preparation of brief 
on the merits for 
United States Supreme 
Court, 

Preparation and filing of 
motion in opposition to 

defendants' application for 
stay in the United States 
Court of Appeals. 

Examination of the record in 
the Supreme Court and con- 
ferences with the Clerk with 
reference to order and time 

for argument. 

Preparation of memorandum 

in opposition to defendants 
application for stay in the 
United States Supreme Court. 

n n 

Preparation of motion to 
affirm or dismiss in North 
Carolina State Board of 
Education v. 
Bussing Statute case). 

Preparation of reply brief 
in the United States Supreme 
Court. 

Preparation of reply brief 
and preparation for argu- 
ment. 

Preparation for argument in 
the Supreme Court. 

Preparation of reply brief 

-13~- 

64 hrs.* 

30 hrs. 

16 hrs. 

10 hrs. 

1 day 
(Nabrit) 

17 hrs. 

2 days 
(Nabrit) 

Swann (the Anti- 

3 days 
(Nabrit) 

12 days 
(Nabrit) 

26 hrs. 

(Chambers) 

45 hrs. 

(Stein) 

45 hrs. 

27:hrs. 

(Stein) 

$375.00 

600.00 

250.00 

200.00 

400.00 

300.00 

625.00 

700.00 

 



  

102. 

103. 

104. 

105, 

106. 

Date 
  

0-28 thru 

10-5-70 

10-6 thru 

10-9-70 

10-7 thru 

10-13-70 

10-9 thru 

10-13-70 

10-9 thru 

10-13-70 

Time Spent Fee Received 
  

Preparation of brief on 
the merits - North Caro- 

lina Board of Education 8 days 
Vv. Swann. (Nabrit) 

Preparation for argument in 
the Supreme Court in North 

Carolina Board of Education 
Vv. Swann. 4 days 

(Nabrit) 
Preparation for argument and 
argument in the Supreme 
Court in Swann v. Charlotte- 
Mecklenburg Board of Educa- 
tion.  Seihrs., 

(Chambers) 

Preparation for argument;: 
argument in the United States 
Supreme Court in Swann Vv. 
Charlotte-Mecklenburg Board 
of Education and North Caro- 
lina Board of Education v. 

Swann. 5 days 

(Nabrit) 

Assisting Chambers and Nabrit 
in preparation for argument in 
the United States Supreme 
Court. 56 hrs. 

(Stein) 
300.00 

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11. 

12. 

  

& 7/70 

1/22-24/69 

3/9/69 

3/9/69 

3/12~13/69 

Fee for Charles Green to conduct 

demographic study of Charlotte 

Fee for expert witness, Yale 

Rabin, City Planner, for his 

analysis of the city and his 

testimony in the case. 

Travel expenses for Yale Rabin. 

Fee for educational consultant 

and witness, Dr. Jack Larsen, 
for analysis of the school sys- 

tem, development of desegregation 

proposals and testifying at hear 

ing. . 

Travel expenses for Dr. Jack 

Fee for educational consultant 

and witness, Dr. Robert Passey, 

for analysis of the school sys- 
tem, development of desegregation 

proposals and testifying at hear- 

Travel expenses for Dr. Robert 

III. litigation Expenses.?* 

1. 7-10/68 

$2. 1968-1969 

3. 1968-1969 

4, 1-3/69 

5. 1-3/69 

Larsen. 

6. 1-3/69 

ing. 

7. 1-3/69 

Passey. 

8. -1-3/69, 3/70 

Fee for educational consultant, 

and witness, Dr. John Finger, 

for analysis of the school system 

development of desegregation pro- 

posals and testifying at hearing. 

Travel expenses for Dr. Finger. 

Travel expenses for educational 

experts in Charlotte. 

Travel expenses for educational 

experts in Charlotte. 

Duplicating expenses for exhibits 

Duplicating costs for exhibits. 

  

or 

$ 2,400.00 

400.00 

161.71 

1,875.00 

333.05 

1,475.00 

427.60 

2,200.00 

1,240.30 

17.40 

14.68 

17.60 

28.32 

All of the expenses shown in this section were either paid by 

reimbursed by the NAACP Legal Defense and Educational Fund, Inc. 

 



  

14. 

15. 

16. 

17. 

18. 

19, 

20. 

21. 

23. 

24, 

25. 

26, 

27. 

28. 

3/9~13/69 

3/15-16/69 

3/21/69 

3/21/69 

4/30/69 

6-11-69 

6-12-69 

6/16-19/69 

7/9-10/69 

6/22/69 

7/25/69 

8/11/69 

9/11/69 

1/15/70 

2/13/70 

Expenses for conducting tour of 

the schools for educational 

consultants. 

Expenses in touring Charlotte 

with City Planner, Yale Robin 

Rental of calculator to prepare 

exhibits and briefs in connection 

with hearing. 

Payment to Court Reporter for 

depositions taken in connection 

with hearing. 

Payment to Court Reporter for 

transcript of hearing. 

Witness fees paid for hearing 

on that date. 

Witness fees paid for hearing 

on that date. 

Xerox costs for plaintiff's sub- 

missions filed with the Court. 

Trip to New York (Chambers) con- 

ferences concerning preparation 

of supplemental complaint attack- 

ing anti-busing statute. 

Payment to Marshal for service 

of subpoenas. 

Payment to Court Reporter for 

transcript of hearing in June, 
1969. 

Payment to Marshal for service 

of subpoenas in connection with 

hearings in August, 1969. 

Payment made to Court Reporter 

for transcript of August, 1969 

hearing. 

Xeroxing of material in connec- 

tion with hearing. 

Xeroxing of state law suit brought: 

by Concerned Parents Association. 

75,92 

20.67 

19.76 

522.90 

509.25 

180.00 

140.00 

24.00 

113.59 

31.40 

482.80 

16.00 

72.75 

10.00 

23.50 

 



  

29. 

30. 

31. 

32. 

33. 

34. 

35. 

36, 

37. 

38. 

39. 

40. 

41. 

42. 

2/20/70 

2/20/70 

3/1/70 

3/3-4/70 

3/3/70 

3/5/70 

3/6-9/70 

3/9/70 

3/10-15/70 

3/10-15/70 

3/10-15/70 

3/16/70 

3/16/70 

3/17-18/70 

Travel expenses in connection 

with trip to Raleigh to depose 

Mr. Dark concerning transportation. 

Air fare to Raleigh. 

Air fare New York - Charlotte, 

Nabrit. 

Expenses incurred in trip to 

Richmond, Virginia, to file re- 

sponse in opposition to defend- 

ants' application for stay. 

Xeroxing of opposition to appli- 

cation for stay. 

Payment to Court Reporter for 

transcripts of depositions taken 

for and introduced at February 

1970 hearings. 

Travel expenses in connection with 

trip to New York to prepare appli- 

cation for vacation of stay, 

Chambers and Stein. 

Witness fees paid for depositions 

taken on March 11. 

Xerox costs for preparation of 

charts and exhibits for hearing. 

Additional secretarial assistance. 

Purchase of maps from city. 

Payment to Marshal for service of 

subpoenas. 

Payment to Court Reporter for trans- 

cripts of depositions used at 

hearing. 

Transportation costs in connection 

with trip to Chapel Hill to secure 

information from library concerning 

state and national school trans- 

portation statistics. 

60.02 

35.70 

96.60 

120.00 

20.00 

300.20 

357.05 

48.00 

300.00 

105.00 

249,00 

57.84 

I
E
R
 
I
 

ER
 

4
 

B
R
A
 

A 
IR

 
Me
 

S
S
I
S
 

T
T
 

0 
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US
A 

1 
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IT
B 

50 

 



  

43. 

44, 

45. 

46, 

47. 

48. 

49, 

50. 

51. 

52. 

53. 

54. 

55. 

56. 

3/16-19/70 

3/23-25/70 

3/26/70 

3/27-4/6/70 

4/1/70 

4/7/70 

4/7/70 

4/9/70 

4/7-9/70 

4/13/70 

4/13/70 

4/14/70 

6/1/70 

6/1-3/70 

Reproduction of exhibits supplied 
by the state board of education 

introduced at hearing. 

Xeroxing of submissions to the 
Court. os 

Xeroxing of opposition of motion 

for stay. 

Additional secretarial expenses 

for preparation of expedited brief 

in Court of Appeal. 

Charlotte - New York air fare - 

Nabrit. 

Air fare Charlotte to Richmond - 

Chambers. 

Air fare New York to Richmond - 

Nabrit. 

Air fare Richmond to New York 

City - Nabrit. 

Travel and hotel expenses in 

Richmond in connection with argu- 

ment in the Court of Appeals, 

Chambers and Stein. 

Payment to Court Report for 

transcript of deposition for 

March hearing. 

Payment to Marshal for service of 

subpoenas for March hearing. 

Payment to Court Reporter for trans- 

cript of depositions taken in con- 

nection with March hearing. 

Air fare Charlotte to New York, 

Chambers, for petition for Writ 

of Certiorari to the U. S. Supreme 

Court. 

Expenses for meals and lodging 

in New York - Chambers. 

600.00 

20.00 

30.00 

204.85 

107.10 

25.20 

54.60 

54.60 

283.04 

40.60 

12.00 

249.10 

86.10 

120.76 

  

 



  

57. 

58. 

59. 

60. 

61, 

62. 

83, 

64. 

85, 

66. 

57. 

6/8-12/70 

6/11-15/70 

6/16-17/70 

7/8/70 

7/13/70 

7/13-17/70 

7/13/70 

7/28-31/70 

7/30/70 

8/4-8/70 

8/11-12/70 

Air fare, meals and lodging in 

New York in connection with pre- 

paring Petition of Writ of 

Certiorari - Stein. 

Air fare, meals and lodging in 

Yew York in connection with pre- 

paring Petition for Writ of 

Certiorari - Chambers. 

Air fare, meals and lodging in 

New York in connection with pre- 

paring Petition for Writ of 

Certiorari - Stein. | 

Xeroxing of exhibits for July 

hearing. 

Payment to Dr. Finger for travel 

expenses to attend deposition. 

Xeroxing costs of additional 

exhibits for hearing. 

Air fare New York - Charlotte, 

Nabrit. 

Air fare, meals and. lodging in 

New York in connection with pre- 

paration of brief for the United 

States Supreme Court - Chambers, 

Stein. 

Payment to Court Reporter for 

transcripts of depositions used 

at July hearing. 

Air fare, meals and lodging in 

New York in connection with pre- 

paration of brief for United 

States Supreme Court, Chambers, 

Stein. 

Air fare, meals and lodging in 

New York in connection with pre- 

paration of brief for the United 

States Supreme Court, Stein. 

170.80 

187.10 

161.06 

116.03 

136.00 

48.53 

90.00 

350.87 

354.20 

454,93 

155.33 

 



  

68. 

69. 

70. 

71. 

22. 

73. 

74. 

75, 

76. 

77. 

78. 

8/20-23/70 

8/20-23/70 

9/23-25/70 

9/23-25/70 

9/21-28/70 

9/28/70 

9/30-~10/4/70 

9/30-10/2/70 

10/7-14/70 

10/9-14/70 

10/9-14/70 

Air fare, meals and lodging in 

New York in connection with pre- 
paration of memorandum in oppo- 

sition to stay in the United 

States Supreme Court (Stein), 

Meals and lodging, Chambers, 

Air fare to New York - Chambers. 

Trip to New York for preparation 

Of reply brief for the U. S. 

Sux eme Court - Chambers. 

Air fare to New York - Chambers. 

Air fare, meals and lodging, New 

York, for preparation of reply 

brief in Swann v Charlotte-Meck- 

lenburg and respondent's brief 

in N. C. State Board of Education 

v Swann, Stein. 

Payment to Court Reporter for 

transcript of proceedings of 

July hearings. 

Trip to New York in preparation 

for arguments in Supreme Court, 

air fare, meals and lodging, 

Chambers. 

Trip to New York in connection 

with work on briefs and arguments, 

air fare, lodging, Stein. 

Trip to Washington, D. C. for 

preparation of arguments in the 

U. S. Supreme Court, air fare, 

meals and lodging - Chambers. 

Trip to Washington, D. C. in 

preparation for arguments in the 

U. S. Supreme Court, Nabrit, 

air fare 

Trip to Washington, D. C. to 
assist Chambers and Nabrit in pre- 

paration of arguments in the U. S. 

Supreme Court - Stein. 

251.08 

86.10 

252.63 

86.10 

563.28 

945.20 

197.10 

247.88 

614.22 

48.00 

338.69 [||dbd85691-9ee7-4673-993d-65b9a3642e6c||]