Wheeler v. Durham Board of Education Reply Brief for Appellants, Warren H. Wheeler, et al.

     [||c3a5514b-bb9f-4522-92c9-b732712795f2||] IN THE UNITED STATES COURT OF APPEALS 

FOR THE FOURTH CIRCUIT 

Nos. 77-1835 and 77-1836 
h 

WARREN H. WHEELER, et al., 

and C. C. SPAULDING, et al., 

Appellants, 

Vo 

A 

THE DURHAM CITY BOARD OF 

EDUCATION, et al., 

Appellees. 

Appeal From the United States District Court 
For the Middle District of North Carolina 

EPLY BRIEF FOR APPELLANTS, WARREN H. WHEELER, et al. 

J. LEVONNE CHAMBERS : at ed, He WHEELER ©.» 7 
LOUIS L. LESESNE, JR. Coen aeti ni 116 West Parrish Street 
JONATHAN WALLAS Josie Sas ©, nmooiparham, North Carolina 
Chambers, Stein, Ferguson & Becton, P.A. gd 2 
951 South, Independence Boulevard 
‘Charlotte, North Carolina 28202 

JACK GREENBERG 2 Ye rE Wn A, MARSH, JR. 
JAMES N. NABRIT, III SiR er 3031/2 8, Chapel Hill 
10 columbus Circle ET nat real U0 
New York, New York 10019 | ind yu BEERet North Carolina 

Attorneys for Appellants, 
Warren H. Wheeler, et al. 



IN THE UNITED STATES COURT OF APPEALS 

FOR THE FOURTH CIRCUIT 

Nos. 77-1835 and 77-1836 

WARREN H. WHEELER, et al., 

and C. C. SPAULDING, et al., 

Appellants, 

Ve 

THE DURHAM CITY BOARD OF 

EDUCATION, et al., 

Appellees. 

Appeal From the United States District Court 

For the Middle District of North Carolina 

REPLY BRIEF FOR APPELLANTS, WARREN H. WHEELER, et al. 

J. LEVONNE CHAMBERS ; J. H. WHEELER 

10UIs L. LESESNE, JR. 116 West Parrish Street 

JONATHAN WALLAS Durham, North Carolina 

Chambers, Stein, Ferguson & Becton, P.A. 

951 South Independence Boulevard 

Charlotte, North Carolina 28202 

JACK GREENBERG WILLIAM A. MARSH, JR. 

JAMES N. NABRIT, III 203 1/2 EB. Chapel Bill 
10 Columbus Circle Street 

New York, New York 10019 Durham, North Carolina 

Attorneys for Appellants, 

Warren H. Wheeler, et al. 



TABLE OF CONTENTS 

TABLE OF AUTHORTIT TES mm mm msm so ree sm sm rm sm ot ot mm mt sot mt st mt tt to me mm mm nm ‘7 

ARGUMENT 

1. The City Board misconstrues the Supreme 

court's decision in Bradley v. Richmond 

SChOOl BOAYQememmm mmm mmm em mn mm om om mmm me em mm mm 2 

2, :219388 is npplicable tO this CASemwwwmwmmmmmmt mmm 5 

3. There are no special circumstances existing 

in this case to justify denying plaintiffs 

fees FOr Pre«l972 SOT VICES ww mmmmmmnasms osm ston mt umm wes atm oto vo oer 6 

4. Plaintiffs are entitled to be compensated 

for reasonable litigation SXDSYISEE mmm wn mmmmn me wr us msm may 8 

5. Plaintiffs are the prevailing party herein 

and are entitled to fees for all services 

rendered Since JUlY 1, 1972 mmununsnmmmm mmo monn ce vu iors versm oss mos som ie me os 9 

CONCILUS T ON mmm om om om mmm em mm mm mm mm mm mm mm mm mmm mm mm mm 14 

CERTIFICATE OF SERVICE= === mmm mmm mm mm mm mm mm mm om mm mm mm 15 



TABLE OF AUTHORITIES 

CASES: 

Armstead v. Starkville Municipal Separate 

School District, 395 F. supp. 

304 {N. D. MIRE. 1078) ure vinr ve sin sain cwiinnisas vniv eines 3 

Bradley v. Richmond School Board, 416 

U.S. 696 (1974) usin vin TR OMNI CP TEENIE RN 2s 3,4. 76, 

Davis v, County of [os Angeles, 8 ErD 
§ 9444 {C.D.Cal, 1974)... ves sinnn EL TR ESSE Ly 1} 

Grier v. Specialized Skill, Inc., 326 

FP. supp. 856 AWD. B.C. 1971) ceesnsioversinnsnsvussin wv. 

Johugon v., Combs, 471 FP.28 84 

{BER CIS 1072) iiss aleve rR ER el SE 2, '3 

Johnson v. Georgia Highway Express, Inc., 

488 R.26 714 {B3ChiCly. 1974)... 0s ist vines aninnssn 13 

Johnson v. Railway Express Agency, 421 

U8, A848 H1075Y ov vie sad env prvinivinsve snivie spin vss vn 5 

Jones v. Mayer Co., 392 U.S. 409 (1968)... veer evrerersnnes 5 

Lytle v. commissions of Election of 

Union County, 541 F.2d 421 

{4th Cir. 1975) {petition for 

cert. DEn@ing). cover veorivenssnssitssssconesanenions 9, 10 

Scott v. Winston-Salem/Forsyth County 

Board of Education, 400 F. Supp. 

65 (M.D.N.C. 1974), affd., 530 

F.28 969 (4th Cir. 1075) selene s cnnimenoivision en rinsy on 2 

Stanford Daily v. Zurcher, 64 F.R.D. 680 

AR. D.C. IT h  einicav ciunivt ms vnnisbisineenseeivesniesio ue 11, 12 

Cnt i id ih ae i Sat TIN ASR BN ih vol Be Cl ERY Bh i AS 3h igs ie nit 



Swann v. Charlotte-Mecklenburg Board of 

Education, 66 F.R.D. 483 

(WD. B.C, 1978) innniviswnsvaisitrnvinsvsssnsscssvinns 11, 12 

Thompson v. School Board of City Of 

Newport News, Virginia, 472 

P.24 177 44th Cir. 1972). vans nrssnsinsrsevrivesas 2,:3,:6,.7 

wade v. Mississippi Cooperative 

Extension Service, 378 F.Supp. 

1251 (AR.D.Mi88. 1975) veer srrsrsssidonsrsvassisninsn 12 

STATUTES: 

Ae Bar. ISB. ls a sheen 5, 6 

Ao a o GIORD ss dhe aa nid A Bes SH ss Mie a nn eis 5 

WE THIN DLS Re Te lm SE gh 5,06 

A Ren eGR Cl nN 5 

SB. Br, WEBLO. et a ade in ne ele ns ed sane Se ni 5 

ii 



IN THE 

UNITED STATES COURT 
OF APPEALS 

FOR THE FOURTH C
IRCUIT 

77-1835 and 7718
35 Nos. 

= 

WARREN H. WHEELER, et al., and 

Cc. C. SPAULDING, et al., 

Appellants, 

Ve. 

THE DURHAM CITY 
BOARD OF EDUCATIO

N, 

at al., 

Appellees. 

" Appeal From the 
United States 

pistrict Court FOr
 the 

Middle pistrict 
of North Carolin

a 

REPLY BRIEF FOR 
APPELLANTS WARR

EN WHEELER, et al. 

Er 



ARGUMENT 

1. The City Board misconstrues the Supreme Court's decision 

in Bradley v. Richmond School Board. 

Plaintiffs ‘submit that the City Board 3 in its brief 

filed herein has misapplied and misconstrued the Supreme Court's 

decision in Bradley v. Richmond School Board, 416 U.S. 696 (1974) 

and has relied upon cases of this Circuit which were effectively 

overruled by Bradley. The cases of Thompson v. School Board of 

City of Newport News, Virginia, 472 7. 248 177 (4th Cir. 1972) and 

Johnson v. Comps, 471 ¥. 28:84 (5th Cir. 1872), decisions which 

provide the heart of the City Board's §718 argument, were specifi- 

cally disapproved in Bradley. Justice Blackmun specifically stated: 

we must reject the contention that a change in 

the law is to be given effect in a pending case 

only where that is the clear and stated intention 

of the legislature..... Bradley, supra at 715: 

1/ plaintiffs will utilize the same abbreviations in this 

brief that were used in their primary brief. (See Brief 

for Appellants at pp. v-vi) The Brief for Appellants 

Warren H. Wheeler, et al., filed August 4, 1977, will be 

referred to as "Brief for Appellants.” 

is i iii ai Bo iat Cl GE Sa Dither Bi SA a i li hu SP Shut a egies SiC chi ia As ct pan 2 SA 



The Supreme Court then cited Thompson by name, in footnote 20, 

as an example (along with Johnson v. combs) of cases resting 

on the very erroneous contention rejected in Bradley. This 

Court's opinion in Thompson centers on the lack of any expressed
 

congressional intent to apply the statute retrospectively 472 

Fr. 2d:at 178. In view of the Supreme Court's explicit rejection 

of the Thompson approach, the reliance placed on that case by the 

city Board and by the District Court here is misplaced. Plaintiffs 

submit that, for the sake of clarity, this Court should explicitly 

hold that Thompson is no longer controlling in this Circuit. 

Furthermore, the City Board inappropriately attempts to 

limit the holding of Bradley to those cases where a fee award 

question was pending on appeal as of July 1, 1972. As pointed out 

in the Brief for Appellants at pp. 12-15, the pertinent question 

is whether or not a final judgment with respect to fees has ever 

been entered in this proceeding (and the time to appeal has 

expired), not whether the request for fees was on appeal (rather 

than pending in the District Court) at the time §718 was enacted. 

See Armstead v. Starkville Municipal Separate School Digtrict, 

395 7, Supp. 304, 308 (%. D. Miss. 1973). 

The position advanced by the City Board would require the 

anomalous result that §718 would be retroactively applied to 

cases where the statute was not effective at the time the 
District 



Court ruled on the fee award but would be only prospectively 

applied in those cases where the District Court initially ruled 

on a fee question after the effective date of §718. 

Justice Blackmun's opinion in Bradley is directed to the 

more difficult question of whether §718 should be applied retro- 

actively when it became law only after the District Court's fee 

MD
 

decision. Since §718 now provides the basis for reversing a fee 

decision which was otherwise correct at the time of entry, it 

must surely be equally applicable when the District Court renders 

its initial decision after the effective date of that statute. 

Nor is the decision in Scott v. Winston-Salem/Forsyth 

county Board of Education, 400 F. Supp. 65 (M.D.N.C. 1974), afzid. 

530 F. 2d 969 (4th Cir. 1975) controlling here. As pointed out in 

the Brief for Appellants at pp. 14-15, a "final judgment" with 

respect to fees was entered by the District Court in Scott on 

September 19, 1973. That order was not appealed and thus became 

final. A subsequent motion filed by the plaintiffs after the 

Bradley decision attempting to reopen the counsel fee question was 

disallowed by the Court. Plaintiffs submit that the Scott dcolsion, 

in light of Bradley and Congress's subsequent actions with respect 

to counsel fees in civil rights cases, should be limited to its 

own facts. 

RE ft Cs a at ke Son ELSE pe a ad 



2. §1988 is applicable to this case. 

The City Board argues that §1988 does not provide a 

basis for counsel fees in this litigation. As plaintiffs have 

pointed out in the Brief for Appellants at pp. 15-19, there 

is absolutely no support in the legislative history of the 1976 

Act to justify limiting its application only to non-school 

desegregation cases. Tt applies equally to all §198l1 and $1983 

proceedings. The fact that S718 and §1988 provide overlapping 

fee remedies should not be surprising. Similar complementary 

remedies exist in the areas of employment discrimination (Title VII 

of ‘the Civil Rights Act of 1964 + 42:3.,8,C, 820000 ot. geq. and 

42.0.8.C. §logl), discrimination in housing (Title VIII of the 

Civil Rights Act of 1968, 42 U.S.C. §3610 and 42 U.S.C. §§ 1981 

and 1982), and discrimination in public accommodations (Title II 

Of the Civil Rights Act of 1964, 42 U.8.C, §2000a et. seg. and 

42 V.8.C, $1981). See,e.9., Johnson v. Railway Express Adency, 

421 0.8, 454 (1975); Jones v, Maver Co., 392 U.S. 409 (1968): and 

Grier v, Specialized Skillz, Inc.,, 326 F, Supp. 856 (Ww, p.N.C. 1971). 

Moreover, if the defendant's analysis of the statutes 

involved herein is correct, the fee remedy in a school desegregation 

case will be different in scope from that in other civil rights 

cases. The City Board virtually concedes, as it must, that §1988 

ls retroactive, (see Brief for Appellants at pp. 19-24) thereby 

making fees available for all cases pending as of the effective 



date of the 1976 Act. On the other hand, the City Board argues 

that §718 is the exclusive statutory basis for fees in school 

desegregation cases and that Thompson limits counsel fees to 

legal services after July 1, 1972. Such a result is inconsistent 

with Congress' express desire to make fee awards "wniform”, as 

it would reopen the very "gap" which Congress in the 1976 Act 

sought to close. The Court below and the City Board in its 

brief cite no authority to support the conclusion that Congress 

meant §1988, which effectively says "fees should be allowed to 

prevailing plaintiffs in all §1981 and §1983 cases”, to read, 

"fees should be allowed to prevailing plaintiffs in all §1981 and 

§1983 cases except those involving school desegregation." This 

Court should not allow such a tortured misinterpretation of 

Congressional will to stand. 

3S. There are no special circumstances existing in this 

case to justify denying plaintiffs fees for pre-1972 services. 

The argument made by the City Board that plaintiffs are 

not entitled to counsel fees for services rendered prior to July 1, 

1972, explicitly depends on this Court holding that §1988 is not 

applicable to this case and that the Thompson decision-is, after 
Na 

Bradley, controlling law in this Circuit. Plaintiffs have set 

forth previously in this brief,and in the Brief for Appellants, 

arguments demonstrating that §1988 does apply herein and that 



ian e—— 

Thompson has been effectively (if not explicitly) overruled by 

the Supreme Court in Bradley. These arguments need not be 

repeated here. 

Plaintiffs do quarrel, however, with the gratuitous 

conclugion of the City Board in lts brief at p. 10 that Mit is 

obvious that when litigation proceeds in stages, each of which is 

then 'final' as to the rights and obligations of the parties, a 

party can expect to have all collateral issues determined within 

a short period following the Court determination on the substantive 

issues." Plaintiffs submit that the record in this case indicates 

that no hearings were held and no determinations ore made as to 

the questions of costs and counsel fees in this case from 1964 

to 1977. The parties and the Court sidetracked {and appropriately 

so) the collateral question of fees until the substantive litigation 

was completed and the Durham City school Snihn was brought into 

constitutional compliance. While interim fee awards may be 

appropriate, there is no requirement that such awards be sought 

or made. The normal course is for the fee question to be decided 

at gio end of the litigation. As Justice Blackmun stated in 

Bradley, supra at pp. 722-723: 

Surely, the language of §718 is not to be read 

to the effect that a fee award must be made 

simultaneously with the entry of a desegregation 

order. The statute, instead, expectedly makes 

the existence of a final order a prerequisite 

ig 0 

ET nT 



to the award. The unmanageability of a 

requirement of simultaneity is apparent 

when one considers the typical course of 

litigation in a school desegregation 

action.... The resolution of the fee issue 

may be a matter of some complexity and 

require, as here, the taking of evidence 

and briefing. It would therefore be un- 

desirable to delay the implementation of 

a desegregation plan in order to resolve 

the question of fees simultaneously. The 

District Court properly chose not to 

address itself to the question of the award 

until after it had approved the non-interim 

plan for achievement of the unitary school 

system, ie. 

Finally, to the extent that the defendant and the Court 

below relied on the District Court's "discretion" to any fees 

for services prior to July 1, 1972, plaintiffs rely on the Brief 

for Appellants at pp. 25-37. 

4, Plaintiffs are entitled to be compensated for reasonable 

litigation expenses. 

Defendant contends that Congress intended in §1988 and 

§718 to preclude prevailing counsel from recovering such costly 

and ASCSERALY litigation expenses as paralegal services, copying, 

long distance and travel expenses, and other similar items. As 

set forth in detail in the Brief for Appellants at pp. 38-48, 

litigation expenses should be allowed because they are consistent 

with the spirit and intent of the counsel fee statutes, because 

‘they were specifically mentioned as being included as part of 

"attorney's fees" recoverable under §1988 by Congressman Drinan 



(See, Brief for Appellants at p. 39), and because the allowance 

of such expenses may in some instances lower the total costs of 

2/ | 
litigation. -— 

Be Plaintiffs are the prevailing party herein and are 

entitled to fees for all services rendered since July 1, 1972. 

The 2UtY Board, in its appeal, argues that the plaintiffs 

are not the preiai ling party herein with respect to certain issues 

raised since July 1, 1972, and that plaintiffs should not recover 

fees for seeking interdistrict relief. Plaintiffs submit they 

have "prevailed" herein and are entitled to fees for bringing the 

Durham City school system into constitutional compliance. 

The standard in this Circuit for determining the pre- 

vailing party for the purpose of awarding counsel fees is Sot Havel 

in Lytle v. Commissioners of Elections of Union County, 541 F. 2d 

421, 425 {4th Cir. 1976), potition for cert. pending. The standard 

for the award of fees is the same as that for the award of costs 

under Rule 54. If judgment is rendered in favor of a plaintiff, 

he is the prevailing party. Footnote 6 in Lytle sets out the 

appropriate standard and authority: 

Commissioners' contention that to be the 

"prevailing party" Lytle must win on all 

issues is clearly without merit. 

2/ For example, lawyers are making increasing use of 

paralegal assistants in their practices. To deny 

recovery for such reasonable expenses might promote 

the inefficient substitution of a lawyer's time 

where a paralegal's services would be adequate. 

hh 



"although a plaintiff may not sustain his 

entire claim, if judgment is rendered for 

him he is the prevailing party." 6 

J. Moore, Federal Practice 54.70[4], at 

1306-07 & n.3 {24 ed. 1975). ACcord, 

10 C. Wright & A. Miller, Federal 

Practice and Procedure: Civil §2667, at 

129 & n.8 (1971). See, ©.¢., K=2 Ski 

Co, v, Head Ski Co., 506 7.248 471, 477 

(9th Cir. 1974): lewis v. Pennington, 

400 7.28 806, 820 (6th Cir.,), Cert. 

denied, 393 U.S. 983, 89 8.Ct. 450, 21 

LL.B. 28 444 (1968); Sperry Rand Corp. 

v, A~T+0, Inc.,: 58 P.R.D. 132, 135 

(B.D. Va. 1973). (All the authorities 

cited above discuss the "prevailing 

party” concept in the context of Fed. R. 

Civ. P.54. We believe that same analysis 

is applicable to the term as used in the 

statutute.) 

This Court's standard as set forth in Iytle is consistent 

with other authority and the legislative history of §1988. In 

Bradley, supra, at 710, plaintiffs were fully compensated even 

though the District Court rejected their desegregation plan and 

accepte.. that of the defendants. The legislative history of the 

1976 Act indicates that: 

"[i] n appropriate circumstances, counsel fees 

under [the Act] may be awarded pendente lite. 

See Bradley, [supra]. Such awards are 

especially appropriate where a party has 

prevailed on an important matter in the course 

of litigation, even when he ultimately does 

not prevail on all issues. See Bradley, supra; 

Mills v, Electric Auto-~Iife Co., 396 U.S. 

375 (1970), (emphasis added) Legislative 

History at p. ll, (Senate Report at p. 5). 



In Swann v. Charlotte-Mecklenburg Board of Education, 

66 P.R.D, 483, 484 (W.,D.R.C.1975) plaintiffs were awarded fees 

for the entire litigation "as the winners rather than the losers 

of the litigation," even though plaintiffs did not "prevail" on 

every issue becausé, as here, "the result has been the complete 

desegregation of the nar otte-Neghlionknys school system." The 

civil rights attorney's fees provisions, in short, are result- 

oriented. 

The language of Swann was specifically approved in the 

1976 Act: "The appropriate standards...... are correctly applied 

in such cases as Stanford Daily v. Zurcher, 64 F.R.D, 680 (N.D. 

cal, 1974); Davis v. County of Los Angeles, 8 EPD 49444 (C.D. Cal. 

1974): and Swann v. Charlotte-Mecklenburg Board of Education 

[supral...... In computing the fee, counsel for prevailing parties 

should he paid, as is traditional with attorneys compensated by 

a fee-paying client, 'for all time reasonable expended on a 

matter' Davis, supra; Stanford Dally, supra.” (Emphasis added), 

Legislative History at p. 12 (Senate Report at p.6). Davis 

expressly states: 

Since plaintiffs prevailed on the merits and 
achieved excellent results for the represented 

class, plaintiffs' counsel are entitled to 

an award of fees for all time reasonably 

expended in pursuit of the ultimate result 

achieved in the same manner that an attorney 

traditionally is compensated by a fee-paying 

client for all time reasonable expended on 

a matter....8 EPD 9444 at p.50409. 

wl 



I ——————a— 

The District Court's issue-by-issue parsing was also specifically 

rejected in Zurcher, supra, 64 F.R.D. at 684. See also, Wade v. 

Mississippi Cooperative Extension Service, 378 F. Supp. 1251, 

1254 (M.D. Miss, 1975), 

Plaintiffs counsel should not be required to divine the 

exact parameters of a Court's willingness to grant relief. Counsel 

should be encouraged to present vigorous arguments in favor of 

their clients and to seek the maximum appropriate relief. As 

long as no frivolous arguments are presented and plaintiffs 

prevail, counsel should be compensated fer all reasonable time 

expended. 

When the Complaints. were filed in this proceeding, the 

Durham City school system was rigidly and totally segregated. 

After years of difficult and persistent litigation, the system 

finally, on March 1, 1977, was declared unitary. Plaintiffs have 

thus reached their goal and have prevailed in this litigation. 

The latest round of litigation in this case, while focusing on 

the question of interdistrict relief, resulted in a finding by 

this Court that as of 1975, the Durham City school system was 

not yet unitary because the District Court "failed to give due 

Cone ATY RL Lin to 'the ne of all techniques for dakegregation’ 

as enumerated in Swann," 521 F.24 at 1136. Plaintiffs thus 

prevailed in the latest round of litigation and obtained additional 

Hy a 

Mie y gE ” ec i sas Eh ee 



relief to desegregate the pertinent school system. The stated 

purpose of this case, the desegregation of the seytinant school 

district, has been realized; no contention has been or could be 

made that plaintiffs Bide acted frivolously or unreasonably; and 

plaintiffs are, therefore, the prevailing party entitled to a 

reasonable fee award: for all time spent. 

Finally, plaintiffs submit the City Board's appeal on 

this issue may be premature. While the Court below has ruled 

plaintiffs are entitled to counsel fees for services rendered 

since July 1, 1972, Judge Gordon has not yet made a dollar award. 

The District Court has not yet specifically considered the various 

factors relating to a fee award. See Johnson v. Georgia Highway 

Fypregsg, Inc., 48B v.24 714 (5th Cir. 1974). Since plaintiffs 

contend fees should be awarded for pre-1972 services and since 

the District Court has not yet weighed the Varlons pertinent 

criteria in making a final fee award, plaintiffs respectfully 

submit the City Board's appeal might best be left until after such 

a determination below. 

wl De 



CONCLUSION 

For the reasons set forth herein and in the Brief for 

Appellants, plaintiffs respectfully pray that those portions of 

the Order entered in this case on March 31, 1977, denying plain- 

tiffs counsel fees for services rendered prior to July 1, 1972, 

and denying plaintiffs recovery for reasonable litigation expenses 

incurred in this proceeding be reversed and that plaintiffs be 

awarded thelr costs including reasonable counsel fees and expenses 

in this appeal. 

Respectfully submitted, 

eo  Aoullan fl bli 

Jl LeVonne Chambers 

1oRTe 1. Lesesne, Jr. 

Jonathan Wallas 

Chambers, Stein, Ferguson & Becton, P.A. 

730 East Independence Plaza 

951 South Independence Boulevard 

Charlotte, North Carolina 28202 

704/375-8461 

William A. Marsh, Jr. 

203 1/2 E. Chapel Hill Street 

Durham, North Carolina 

J. H. Wheeler 

116 West Parrish Street 

Durham, North Carolina 

Jack Greenberg 

- James N. Nabrit, III 
10 Columbus Circle 

New York, New York 10019 

~ Attorneys for Plaintiffs-Appellants 

wo) de 



"promo. 

& 

3 

CERTIFICATE OF SERVICE 

The undersigned hereby certifies that the foregoing Reply 
Brief has been served On counsel for the defendants below, 
Durham City Board of Education, et al., by serving two Copies 
of said brief on Marshall Spears, Jr., P. 0. Box 270, Durham, 
North Carolina 27702. 

This the 19th day of September, 1977. 

of $ 199 ll SN AA LAA 
JONATHAN WALLAS 

1 
& \ 4 A 

32. 

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