Motion for Permission to File Brief Beyond 70 Pages

Public Court Documents
July 31, 1972

Cite this item
Motion for Permission to File Brief Beyond 70 Pages preview

2 pages

Cite this item

  • Case Files, Milliken Hardbacks. Motion for Permission to File Brief Beyond 70 Pages, 1972. c4744b75-53e9-ef11-a730-7c1e5247dfc0. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/ef98fd8e-eb96-4e6d-9527-45fc4ee120e8/motion-for-permission-to-file-brief-beyond-70-pages. Accessed November 28, 2025.

    Copied!

    #72-8002
UNITED STATES COURT OF APPEALS 

FOR TIIE SIXTH CIRCUIT

RONALD BRADLEY, et al,
Plaintiffs-Appellees,

v
WILLIAM G. MILLIKEN, et al,

Defenaants-Appellants,
and
DETROIT FEDERATION OF TEACHERS, 
LOCAL 231, AMERICAN FEDERATION 
OF TEACHERS, AFL-CIO,

U.S. District 
Court #35257

Defendant-Intervenor,
and _
DENISE MAGDOWSKI, et al,

Defendants-Intervenor,

et al. /

MOTION GRANTED
ENTERED BY THE CLERK PURSUANT

BRIEF BEYOND 70 PAGES

Now come defendants Milliken, Kelley, State Board of 
Education, Porter and Green by their attorneys Frank J. Kelley, 
Attorney General of the State of Michigan, et al, and respect­
fully move this Court for permission, pursuant to F R App P 
28(g), to file a brief in this cause extending beyond 70 type­
written pages for the following reasons:



1. On July 20, 1972, these defendants filed with 
this Court their application for permission to appeal under 
28 USC 1292(b). Such application contained a statement of 
questions or issues that included 13 questions.

2. On July 24, 1972, by order of this Court the 
parties were directed to brief 4 additional questions.

3. These defendants respectfully submit that 70 
pages is an inadequate length for a brief involving these 
17 questions. Further, the voluminous record in this cause 
and the fact that this case involves major constitutional 
law questions affecting 1/3 of the public school pupils in 
the State of Michigan mandates that the questions involved 
herein be thoroughly briefed by the parties for this Court's 
careful consideration in deciding this cause.

this Court to enter an order granting them permission to 
file a brief in this cause/in excess of the- 70 pages pro­
vided by F R App P 2 8(g) . •

Wherefore these defendants respectfully request

Respectfully submitted,

/ '
/ - < -

Robert A. Derengoski 
Solicitor General
Eugene Krasicky 
Gerald F. Young

Assistant Attorneys General
Dated: July 28, 1972 Attorneys for Defendants- 

Appellants
- 2-

Copyright notice

© NAACP Legal Defense and Educational Fund, Inc.

This collection and the tools to navigate it (the “Collection”) are available to the public for general educational and research purposes, as well as to preserve and contextualize the history of the content and materials it contains (the “Materials”). Like other archival collections, such as those found in libraries, LDF owns the physical source Materials that have been digitized for the Collection; however, LDF does not own the underlying copyright or other rights in all items and there are limits on how you can use the Materials. By accessing and using the Material, you acknowledge your agreement to the Terms. If you do not agree, please do not use the Materials.

Additional info

To the extent that LDF includes information about the Materials’ origins or ownership or provides summaries or transcripts of original source Materials, LDF does not warrant or guarantee the accuracy of such information, transcripts or summaries, and shall not be responsible for any inaccuracies.