Draft Response of Heritage School to Objections to Certifications for Eligibility and Motion for Supplemental Relief

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textbooks and would neither admit or deny the allegations as to 

all other schools made a party-~defendant hereto. 

2. This respondent denies that it should return to state 

depositories any state-owned textbooks for the reason that ‘1t 1s 

entirely eligible and complying with all state and federal laws, 

3. This respondent denies that it is ineligible to receive 

publicly owned-textbooks and in support thereof would attach as 

Exhibit 1 to this response, a true and correct copy of the portion 

of the charter of this school which sets out its purpose for in~- 

corporation. | 

i) This! school 13 of very limited funds and 1s unable to af- 

ford paid radio or television advertising but did have some paid 

newspaper advertising, copies of which are enclosed as 'a composite 

Exhibit 2 to this response. Also, some free television and radio 

advertising was obtained by the administrator and others being 

guests on program known as ''Coffee with Judy” on WLBT, Channel. 3 

Television and free radio advertising was obtained by the adminis- 

trator appearing and being interrogated by Mr. Keith Tonkel on 

WSL1 Radio, all in Jackson, Mississippi. 

11) This™idra shsilthon=profit school and’ cannot financial 

afford listing in the Yellow Pages of the telephone book and is 

not listed in the Yellow Pages nor has it ever been. 

7111) 1 This schol maintaihs A stall of four toathery) of whom 

two are white and two are black, namely, Miss Ruth Ann Rolling - 

Black, Mrs. Gwendolyn Patton =- Black, Mrs. Mary Folk Donovan- 

White, ‘and Mrs. Mary R. Bond - White. There is a present student 

enrollment of twenty-two (22) composed of nineteen (19) white, one (1) 

oriental and two! {2)'black. 

jv) Heritage School provides a learning environment to aid all 

the children in this school, whether they be black, white or oriental, 

in overcoming their learning disabilities, or in learning to compen 

sate to the extent that they may function efficiently in a regular 

school situation. The school does recognize and pay tribute to both 

black and white Americans, regardless to color, if''tvibute’ is due. 

The school does not participate in athletic events with any other 

 



  

school as it does not have the correct efirollment to carry on 

Such a prooram.nor financial ability to 40 so." An exercise 

program is maintained and designed to help the students in coordi- 

nation and to facilitate learning and all students participate in 

this program. 

4. Respondent offers the newspaper advertising and the 

dates as proof of its compliance with advertising and its eligi- 

pility for textbooks and would be happy to reconstruct any prior 

years that the Court would require. 

5... This respondent can neither admit nor deny the allega- 

tions of . paragraph five as being entirely without its knowledge. 

1.1%. 

This respondent denies that this Court should Provide an 

order: a) enjoining this defendant-respondent to obtain any sort 

of accounting whatsoever for the reason that it is in full com- 

pliance with all of the State and Federal laws; and Db) denies 

that it should provide and inspection of such tabulations by plain- 

tiff’'s counsel or his representative and would show unto the Court 

that all of this respondent's poBks are open 10 inspection by. any 

responsible group at any time without the necessity of a Court 

order, 

This respondent denies that the relief sought is _necessary for 

the reasons stated above. 

Respectfully Submitted, 

HERITAGE SCHOOL 

BY: 
  

MARY R. BOND, Administrator 

Heritage ‘School 
P. 0. Box 10446, Westland Station 

3 Jackson) 'Mi 834 s'sppd | 139209 

Of Counsel: 

Thomas W. Sanford 

P20. %Box 224853 

Jackson, Mississippi 39205 

STATE OF IMISSTSS IPP] 
COUNTY OF HINDS 

Personally appeared before me, the undersigned authority in and 

 



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for the jurisdiction aforesaid, the within named MARY R. BOND, who 

states on hey oath that ‘she is administrator of Heritage School of 

Jackson, Mississippi and that she has fully and truthfully answer- 

ed each and every allegation of the foregoing Objection to Certifi- 

cation of Eligibility and Motion for Supplemental Relief of the 

plaintiff and that each and every answer or allegation made herein 

is true and correct as therein stated or if based on information and 

belief is verily believed to be true and correct as therein stated, 

SWORN. TO AND SUBSCRIBED RERORE ME, this .iday of October, 

1973, 

  

NOTARY PUBLIC 
8 

My Commission Expires: 
  

CERTIFIGATE 
  

This’ isto" certify ‘that a‘true and correct copy’ of the fore- 

going instrument, has this date been mailed to the Honorable Melvyn 

R. Leventhal of ploy ding Banks, Nichols and Leventhal, 538 1/2 

North Parish Street, Jackson, Mississippi, 39202, by United States 

mail, postage prepaid, and copy of same has also been mailed to 

Jack Greenberg, Suite 2030, 10 Columbus Circle, New York, New York, 

10019, Counsel for Plaintiffs, by United States mail, postage pre- 

paid. 

Dated this day of October, 1973. 

  

 



                                              

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