Affidavit of Lou Sommerville

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FOR THE FIFTH CIRCUIT [oli 

UNITED STATES OF AMERICA 

Plaintiff-Appellant, 

Vv. 

HINDS COUNTY SCHOCL BOARD, 

et og 

Defendants~Appellees 

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DIAN HUDSON, et al., 
CIVIL ACTION 

Plaintiffs-Appellants, NO. 3382 

UNITED STATES OF AMERICA, 

Plaintiff-Intervenor- 

Appellant, 
7a rE 2} A ody iS YC AKE DEP 0S TT IORS 
  

Vv. 

LEAKE COUNTY SCHOOL BOARI 

et al., “-
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Defendants~Appellees. 

  

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TO: All Attorneys of Record 

PLEASE TAKE NOTICE that pursuant to Rule 30 of 

the Federal Rules of Civil Procedure, the United 

States will take the depositions of Mr. H. M. Price 

and Mr, F. F. Munday on May 9, 1972 at 9:00 o'clock a.m. 

the Office of the 

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and 11 o'clock a.m. res 

United States Attorney in Jackson, Mississippi. 

 



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Mr. H. M. Price is requested to bring with 

him the following lists of information or any 

documents, letters, contracts or other written 

indicia reflecting such information: 

1. List of all teachers, coaches, and 

administrators, by race, school, years of 

experience, certification, and grade or 

subject(s) taught, in the enploy of the 

Leake County School System during the 

1970-71 school year. 

2. List of all teachers, coachss, and 

administrators, by race, school, years of 

experience, certification, and grade or 

subject(s) taught, waaitestianed, retired 

or were dismissed (with date of retirement, 

resignation or dismissal) between Sep- 

tember 1970 and the present. 

3. List of all teachers, coaches, and 

administrators, by race, school, years of 

experience, certification and grade or 

subject(s) to be taught which the district 

has presently contracted with or intends to 

employ for the 1972-73 school year. 

4. List.of all teacher, coaching, and 

administrative slots for the 1972-73 school 

year that are presently unfilled. 

 



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5. List of all teachers, coaches and 

administrators, by race, school; years of 

experience, certification, and grade or 

subject(s) taught who were sent letters 

on or about April 1, 1971 informing them 

that their employment with the Leake 

County School System would terminate with 

the completion of the 1970-71 school year, 

along with copies of all such letters. 

6. List of all teachers, coaches, and 

administrators, by race, school, years of 
1 

experience, certification and grade or 

subject (s) taught employed for the 1971-72 

school year who were not employed by the 

district for the 1970-71 school year. 

7. Minutes of Board meetings frou 

January 1, 1971 so uresdnt, 

8. Any objective, non-racial criteria de- 

vised by the district for use in effecting 

necessary dismissals or demotions of faculty 

and staff personnel. 

You are invited to attend and cross-examine. 
RUSE. AS 

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ROBERT E., HAUBERG BRIAN K. LANDSBERG 

United States Attorney JACK RUZICHO 

: BRUCE E. DAVIS 

Attorneys 

Department of Justice 

Washington, D.C. 20530 

 



  

CERTIFICATE OF SERVICE 
  

  

I hereby certify that I have served copies 
of the foregoirg Notice to Take Depositions upon 

the following Counsel of Record by mailing copies 

to them, postage prepaid, at their usual addresses: 

Harold W. Davidson, Esq. 
114 1/2 South Pearl Street 
arthage, Mississippi 39051 

Melvyn R. Leventhal, Esq. 
Anderson, Banks, Nichols and Leventhal 

538 1/2 North Farish Street 
Jackson, Mississippi 39202 

Jack Greenberg, Esq. 
Suite 2030 

- 10 Columbus Circle 
New York, New York 10018 

  

zr ory Wo 3 

“BRUCE Ee DAVIS 
Attorney 
Per srmmens of 

  

Justice & 

Wa shington, D. £2. 20530