Gamble v. City of Dublin, GA Duplicated Record
Public Court Documents
February 21, 1966
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Case Files, Milliken Hardbacks. Response and Brief Supporting Motion for Leave to Proceed on the Original Papers and Dispense with Printed Appendix, 1972. 23899531-53e9-ef11-a730-7c1e5247dfc0. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/c40e4803-0868-4e2a-881f-8f7a717a5a3f/response-and-brief-supporting-motion-for-leave-to-proceed-on-the-original-papers-and-dispense-with-printed-appendix. Accessed May 03, 2025.
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IN THE UNITED STATES COURT OF A P P E A L S
FOR THE SIXTH CIRCUIT
No.
BOARD OF EDUCATION OF THE SCHOOL
DISTRICT OF THE C ITY OF DETROIT, a
school district of the f irs t class,
Appellant,
vs.
RONALD BR AD LE Y, E T A L ,
Appellees .
On Appeal from the United States D istrict
Court for the Eastern D istrict of Michigan
Southern Division
RESPONSE TO MOTION FOR LEAVE TO
PROCEED ON THE ORIGINAL PAPERS
AND TO DISPENSE W ITH PRINTED APPE ND IX
_______AND BRIEF IN SUPPORT THEREOF
Butzel, Long, Gust, Klein & Van Zile
By: W illiam M. Saxton
John B. W eaver
1881 F irs t National Building
Detroit, Michigan 4822 6
Telephone: (313) 963-8142
Attorneys for Appellees A llen Park
Public Schools, et al ,
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IN THE UNITED STATES COURT OF A P P E A L S
FOR THE SIXTH CIRCUIT
No.
BOARD OF EDUCATION OF THE SCHOOL
DISTRICT OF THE C ITY OF DETROIT, a
school district of the f irs t class,
Appellant,
vs.
RONALD BRADLEY, ET A L ,
Appe llees .
On Appeal from the United States D istrict
Court fo r the Eastern D istrict of Michigan
Southern Division
RESPONSE TO MOTION FOR LEAVE TO
PROCEED ON THE ORIGINAL PAPERS
AND TO DISPENSE W ITH PRINTED A PPE N D IX
NOW COME Appellants A llen Park Public Schools, et al, and oppose
the Motion For Leave To Proceed On the Original Papers And To Dispense
With Printed Appendix filed by the Board of Education of the School D istrict
of the City of Detroit, for the following reasons:
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1. The Ruling On Desegregation A rea and Order for Develop
ment of Plan of Desegregation issued by the D istrict Court on June 14, 1972,
affects over 700,000 school children in three (3) counties and fifty-three (53)
heretofore independent school districts.
2. The desegregation remedy decreed by the D istrict Court is
unprecedented in terms of its scope and the admitted lack of evidence that
fifty-two (52) of the schools included in said remedy have been established
or maintained so as to preclude the admission of any child on the basis of
race. .
3. This case is one of imperative public importance and all
parties should be afforded the opportunity to assure that those portions of
the record they deem essential fo r consideration by the Court are placed
before the Court in a manner which w il l assist the Court and facilitate
review.
4. The Detroit Board of Education makes no claim that the
entire record w il l be required to be set forth in appendix fo rm and such
event is highly improbable.
5. Any costs to be assessed in connection with the printing of a
Joint Appendix would, in all likelihood, not be borne entirely by the Detroit
Board of Education but would be shared by the other principal defendants in
this case.
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There is no showing that the6. cost of preparing a Joint
Appendix is so exorbitant as to render the Detroit Board of Education
financially impotent.
7. The public importance of this case mandates that every con
ceivable assistance be rendered to this Court in order to assure an
expeditious and adequate review, including the preparation of an Appendix.
Respectfully submitted,
B U TZE L , LONG, GUST, KLE IN & VAN ZILE
N W illiam M. Saxton
John B. Weaver
Robert M. Vercruysse
1881 F irs t National Building
Detroit, Michigan 48226
Telephone: (313) 963-8142
Attorneys for A llen Park Public Schools, et al
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