Motion for Revised Plan

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* * 
IN THE UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF MISSISSIPPI 

JACKSON DIVISION 

  

BEATRICE ALEXANDER, et al., ) 

Plaintiffs, ) 

Ve. ) CIVIL ACTION 

THE HOLMES COUNTY BOARD OF ) "XO. 3779 
EDUCATION; L. R. THOMPSON ) 
Superintendent of Education, ) 
et al., ' 

Defendants. ) 

i) 
  

MOTION FOR REVISED PLAN 
  

The present plan of desegregation, as adopted and 

implemented by defendants, does not meet the minimum require- 

ments of the Fourteenth Amendment to the United States Con- 

stitution and United States v. Jefferson County Board of 
  

  

Education, No. 23345 (5th Cir., filed Dec. 29, 1966), aff'd   

en banc, March 29, 1967. 

WHEREFORE, plaintiffs respectfully pray that this Court: 

(1) Enter an order adopting the Corrected Decree set 

forth in United States v. Jefferson County Board of Education, 
  

  

No. 23345 (5th Cir., filed March 29, 1967), slip opinion, pp. 

9-24; 

(2) Order defendants forthwith to submit, and implement 

prior to the beginning of the 1967-68 school year, a revised plan 

of desegregation conforming in every respect to the requirements 

of United States v. Jefferson County Board of Education, supra, 
  

  

 



  

which plan shall, inter alia, (a) provide for a thirty day choice 
  

period commencing May 1, 1967, or as soon thercafter as this Court 

may order, notwithstanding that a choice period not meeting the 

requirencnts of the Corrected Decree has already been held, and 

(b) include specific provisions for the dcscgregation of teachers 

and other personnel for the 1967-68 school year; 

(3) Order defendants, not later than fiftcen days following 

the closc of the choice period, to serve upon opposing counscl 

and file with the Clerk of this Court the reports required by 

section IX(1l) of the Corrected Decree. 

(4) Grant an early hearing on this Motion, and on such 

hearing grant the relief prayed for herein and such other, further, 

and additional relief as may appear to the Court equitable and 

Just. 

Respectfully submitted, 

[s/] MARIAN E. WRIGHT 

MARIAN E. WRIGHT 
PAUL BREST 
IRIS BREST 

538% North Farish Street 
Jackson, Mississippi 39202 

  

JACK GREENBERG 
Suite 2030 
10 Columbus Circle 
New York, New York 10019 

Attorneys for plaintiffs 

CERTIFICATE OF SERVICE 

I hereby certify that on this 8th day of April, 1967, I 

caused to be scrved by United States mail, postage prepaid, a 

copy of the foregoing Motion for Revised Plan upon all attorneys 

appcaring in this action. 

[s| MARIAN E. WRIGHT 

  

MARIAN E. WRIGHT