Series I. Alphabetical Files, 1950-1994 (1975-1990)
31 box(es)
(29.5 linear feet and 9 audiovisual items)
Series I. Alphabetical Files consists of a discrete set of files created by Weekes & Candler related to the case, especially related to if unitary status (desegregation) had been achieved. The majority of the files are case exhibits and data collected about the school system, as well as research files, correspondence, depositions, federal compliance reports, testimony, and other case files. Common subjects include the quality of education in DeKalb County Schools, school policies, enrollment numbers of students including race, statistics on teachers and staff, and attendance boundaries. This series is open for research with the following exceptions. Boxes with restricted materials are identified with an R before the box number. An access restriction note follows each restricted folder title with an explanation of the restriction and when the folder will be open. 1. Attorney-client privileged materials are restricted for 50 years from the date of the folder. 2. Folders with large numbers of social security numbers are currently restricted. 3. Some boxes in this series must be reviewed for account numbers or social security numbers prior to research use. Please request these boxes 3 business days prior to your research visit to allow time for this review. 4. Reference copies of the audiovisual recordings are available upon request. Research requests will be filled as soon as possible and will be dependent upon the condition of the recordings. This alphabetical run was reconstructed using documentation from the donor, including a divider at the beginning of each letter of the alphabet and filing notes about groups of files that were housed in separate locations. The group of files in the "Unitary Status" section was originally housed separately and was returned to the appropriate location using the filing notes. There was another group of files with a filing note called "Redan". These files were not found during processing, although there are other files related to Redan High School in Series III. Working Files. box folder Request box R.29 1 DeKalb County Board of Education (Pitts v. Cherry- Personnel, Building, Etc. Analysis for 1978-79 School Year), 1978-1979
This folder contains restricted attorney-client privileged records and is open for research on January 1, 2030. box folder Request box R.1 1 B/E Pitts, Attendance Areas, Attendance Area Changes by Year Index Included 1963-64 thru 1986-1987 Volume I, circa 1987 R.1 2 B/E-Pitts, Attendance Areas, Maps of Attendance Area Changes, 1979 box folder Request box 30 2 [Maps of Attendance Areas], 1969-1986 box folder Request box R.1 3 B/E-Pitts, Attendance Areas, Miscellaneous Documents, 1969-1985 R.1 4 B/E- Pitts v. Freeman- Attorney's Fees Issue, 1977-1978 R.1 5 Pitts v. Cherry- Bi-Racial Committee Documents, 1977-1983 R.1 6 Bi-Racial Committee Responsibilities, 1978 May 15 R.1 7 B/E Pitts v. Cherry- Bi-Racial Committee Documents, 1973-1986 box folder Request box R.29 2 B/E Pitts v. Cherry- Biracial Committee Correspondence, 1977-1983
This folder contains restricted attorney-client privileged records and is open for research on January 1, 2034. box folder Request box R.1 8-14 Bi-Racial Minutes Renfroe, 1977-1983 R.1 15 B/E Pitts v. Cherry- Board of Education Meetings, 1980-1981 R.1 16 #1-443 B/E Pitts v. Freeman- Bond Referendum (98,000,000.00), 1989-1991 R.1 17 B/E Pitts v. Freeman- Briarcliff High, M to M Problem, 1986 R.1 18 B/E Pitts v. Freeman- Briarcliff Elementary School Issue, 1985 R.1 19 B/E Pitts Capacity Figures, Misc., 1979-1981 R.1 20 Correspondence and Memos, 1991 box folder Request box R.29 3-4 Correspondence 1990 Vol. I and II (2 folders), 1990
These folders contain restricted attorney-client privileged records and are open for research on January 1, 2041. R.29 5 B/E Pitts, Unitary Status- Correspondence, 1988, 1988
This folder contains restricted attorney-client privileged records and is open for research on January 1, 2039. box folder Request box R.1 21 B/E Pitts v. Freeman Correspondence, 1987 box folder Request box R.29 6 B/E Pitts v. Freeman- 1986 Correspondence, 1986
This folder contains restricted attorney-client privileged records and is open for research on January 1, 2037. R.29 7 B/E Pitts v. Cherry- 1985 Correspondence, 1985
This folder contains restricted attorney-client privileged records and is open for research on January 1, 2036. box folder Request box R.1 22 B/E Pitts v. Cherry Correspondence, 1984 R.1 23 B/E Pitts v. Cherry Correspondence, 1976-1983
This folder must be reviewed for account numbers prior to research use. Please request this box 3 business days prior to your research visit to allow time for this review. R.1 24 Desegregation Plans- Other Systems (Misc.), 1989-1990 box folder Request box 2 1 #1-443 B/E Pitts v. Freeman Curriculum- High School, 1990 #1-443 B/E Pitts v. Freeman Desegregation Plans- Other Systems box folder Request box 2 2 Charlotte, 1969-1988 2 3 San Diego, 1988-1990 2 4 Cleveland, 1984-1988 2 5 Duval County, 1990 2 6 Borowski, 1986-1989 2 7 Oklahoma, 1989-1991 2 8 B/E Pitts v. Cherry- Docket, 1976-1984 2 9 Documentary Evidence Not Admitted- Willie Pitts, et al. v. Jim Cherry, et al. CA 11946, 1966-1969 2 10 B/E- Pitts, Exhibit Research- Status of all Exhibits, One 1968 Exhibit, 1978-1986 2 11-13 B/E Pitts v. Cherry Expenses, 1985-1989 2 14 B/E Pitts v. Cherry- Index Enrollment Documents, Miscellaneous, circa 1993 2 15-16 B/E Pitts v. Cherry- Enrollment Documents, Miscellaneous, 1970-1993 2 17 B/E Pitts v. Cherry Compiled Enrollment [1976-1983], circa 1993 2 18 B/E- Pitts, Federal Completed Report Students, Actual, 1972
Data includes enrollment numbers for each school. First divided by grade and special education. Within each grade divided by race (white, black, other). box folder Request box 3 1-3 B/E-Pitts, Federal Compliance Report Students, Actual, 1973-1975
Data includes enrollment numbers for each school. First divided by grade and special education. Within each grade divided by race (white, black, other). box folder Request box R.29 8 B/E-Pitts, Federal Compliance Report Students, Actual, 1976
Data includes enrollment numbers for each school. First divided by grade and special education. Within each grade divided by race (white, black, other).
This folder contains restricted attorney-client privileged records and is open for research on January 1, 2027. box folder Request box 3 4-17 B/E-Pitts, Federal Compliance Report Students, Actual, 1977-1990
Data includes enrollment numbers for each school. First divided by grade and special education. Within each grade divided by race (white, black, other). 3 18-23 B/E-Pitts, Federal Compliance Report Students, Anticipated, 1985-1990
Data includes enrollment numbers for each school. First divided by grade and special education. Within each grade divided by race (white, black, other). box folder Request box R.4 1-10 B/E-Pitts, Federal Compliance Report Students, Anticipated, 1974-1984
Data includes enrollment numbers for each school. First divided by grade and special education. Within each grade divided by race (white, black, other). R.4 11-31 B/E-Pitts, Federal Compliance Report Faculty, Actual, 1969-1989
Data includes enrollment numbers for each school. First divided by grade and special education. Within each grade divided by race (white, black, other). R.4 32-40 B/E-Pitts, Federal Compliance Report Faculty, Anticipated, 1988-1974
Data includes enrollment numbers for each school. First divided by grade and special education. Within each grade divided by race (white, black, other). box folder Request box R.29 9 Pitts v. Cherry 1977- Flat Shoals Boundary Change, 1977-1980
This folder contains restricted attorney-client privileged records and is open for research on January 1, 2031. box folder Request box R.4 41 B/E Pitts v. Cherry Gordon High School, 1972 R.4 42 B/E Pitts v Cherry HEW [U.S. Department of Health, Education, and Welfare] Correspondence, 1968-1976
This folder contains restricted attorney-client privileged records and is open for research on January 1, 2030 box folder Request box R.29 10 Pitts v. Cherry (Heritage School), 1978
This folder contains restricted attorney-client privileged records and is open for research on January 1, 2029. box folder Request box R.4 43 #1-443 B/E- Pitts v. Freeman- Intervention- NAACP Deposition Notes, 1990
This folder contains restricted attorney-client privileged records and is open for research on January 1, 2030 R.4 44 #1-443 B/E- Pitts v. Freeman- Intervention- NAACP Roger Mills, 1989-1990 R.4 45 #1-443 B/E- Pitts v. Freeman- Intervention- Parents Deposition Notes, circa 1990
This folder contains restricted attorney-client privileged records and is open for research on January 1, 2030 R.4 46 #1-443 B/E- Pitts v. Freeman- Intervention- Research, 1990
Legal memo regarding class dissent and representation. R.4 47 #1-443 B/E- Pitts v. Freeman- Intervention- Ross Report, 1990
Poll of black parents in the DeKalb County School System on "The Future of Secondary Education in the DeKalb County School System". R.4 48 #1-443 B/E- Pitts v. Freeman- Teacher Intervention- General, 1988-1989 box folder Request box R.51 2 #1-443 B/E- Pitts v. Freeman- Teacher Intervention- Teacher Contracts, 1989
Data fields are School Department Name, Employee Name, SSN, Years of Service, Cert. Type 1., IC Code
This folder contains a large number of social security numbers and is currently restricted. box folder Request box 5 1 #1-443 B/E- Pitts v. Freeman- Intervention- Teacher- Attorney Notes (Burnette), 1990 5 2 #1-443 B/E- Pitts v. Freeman- Intervention- Teacher- Lottery (EEOC Charge), 1990 5 3 B/E, Pitts v. Freeman- Junior High Information, circa 1994 box folder Request box R.29 11 B/E Pitts v. Freeman- Kindergarten, Full-Day, 1985
This folder contains restricted attorney-client privileged records and is open for research on January 1, 2036. box folder Request box 5 4 B/E Pitts v. Freeman- Kindergarten and Special Education, Correspondence, etc., 1978-1979 5 5 B/E Pitts v. Cherry- M-to-M Information Re: Kindergarten and Special Education, 1978 5 6 Pitts v. Cherry (Knollwood), 1969-1984 5 7 Pitts v. Cherry- Lakeside High School- Acts Taken Re: Waiting List and Present Enrollment, 1982-1983 5 8 Pitts v. Cherry- Attorney Notes, Depositions- Lakeside, 1983 5 9 Pitts v. Cherry- Bill Day- Lakeside Issue- Dr. McGuffey, 1983 box folder Request box R.29 12 B/E Pitts v. Freeman- Lakeside- Correspondence, 1984-1986
This folder contains restricted attorney-client privileged records and is open for research on January 1, 2037. box folder Request box 5 10 Pitts v. Cherry- Deposition of Dr. William Stewart Adams, 1983
Adams was Assistant Superintendent of Planning and Development for the DeKalb County School System. The deposition focuses on Lakeside High School, Knollwood, and Redan, and how the M-to-M program affects Lakeside and vice versa. 5 11 Pitts v. Cherry- Deposition of Dr. Edward Bouie, 1983
Bouie was Assistant Superintendent for Community and Staff Relations. In that role he worked directly with the Department of Communications and the Department of Student Services and oversaw the administration of the M-to-M program. 5 12 Exhibits Identified in the Deposition of Dr. William S. Adams- Pitts vs. Cherry, et al.; Civil Action File No. 11946, 1983
Includes enrollment data with analysis to identify areas of overcrowding and discussion of changes to be made. 5 13 Pitts v. Cherry- Deposition of Dr. William Day, Deposition of Dr. Robert R. Freeman, 1983
Day was an Associate Professor in the Department of School Administration at Indiana University in Bloomington with expertise in the area of school facility planning. Freeman was Superintendent of DeKalb County Schools and the deposition focuses on Lakesi 5 14 Exhibits Identified in the Deposition of Dr. Robert Freeman- Pitts, et al., vs. Cherry, et al.; Civil Action File No. 11946, 1983
Includes enrollment data and memos related to identifying areas of overcrowding, the M-to-M program, and potential changes to schools to achieve desegregation. 5 15 Pitts v. Cherry- Deposition of John Kicklighter, 1983
Kicklighter was principal of Lakeside High School. The deposition focuses on the M-to-M Program at Lakeside. 5 16 Pitts v. Cherry- Deposition of Dr. Carroll Wade McGuffey, Sr., 1983
McGuffey was a Full Professor of Education Administration at the University of Georgia. The deposition focused on the number of teacher stations and the utilization of space at Lakeside High School. 5 17 Pitts v. Cherry- Deposition of Roger Mills, 1983
Mills was attorney for the plaintiffs and a member of the Biracial Committee. The deposition focuses on decisions of the Biracial Committee. 5 18 Pitts v. Cherry- Deposition of H. Paul Womack, Jr., 1983
Womack was Chairman of the DeKalb County Board of Education. The deposition focuses on a meeting on January 24th about support for the middle-school concept and the M-to-M Program at Lakeside High School. 5 19 Pitts v. Cherry- Druid Hills, 1981-1983 5 20 B/E Pitts v. Freeman- Lakeside- Executive Session A, 1983 5 21 B/E Pitts v. Freeman- Lakeside - Exhibits, 1983 5 22 B/E- Pitts v. Freeman- Lakeside- M to M, 1982-1984 5 23 Documents on M to M, 1976-1984 5 24 Pitts v. Cherry- Lakeside High School- Pleadings for Injunction, 1983 5 25 Joe Renfroe- Lakeside Witness, circa 1983 5 26 Pitts v. Cherry August 83 Transcript September 1983 Order, November 1976 Order and June 1969 Order, 1983 5 27 B/E Pitts v. Cherry- Report of Teacher Stations at Lakeside, 1983 5 28-29 B/E Pitts v. Cherry- Research- Attorney's Notes- Lakeside, 1978-1983 5 30 Pitts v. Cherry (Lakeside Test Scores, Comparisons, etc.), 1982-1983 5 31 B/E Pitts v. Cherry - Lakeside- Trial Brief, 1983 5 32 #1-443 B/E - Pitts v. Freeman- M-to-M DeKalb County General, 1990-1992 box folder Request box 6 1 Pitts v. Cherry- M-to-M Brochures, 1977-1992 6 2 Pitts v. Cherry M-To-M Documents, 1981-1983 6 3 Pitts v. Cherry (Documents After 3/1/83 Re: M-to-M Cutoff), 1983 6 4 M to M Volume III (Renfroe), 1979-1983 6 5 Pitts v. Cherry M-to-M Memos and Chart Volume I, 1976-1981 6 6 Pitts v. Cherry (M-to-M Volume II), 1981-1983 6 7 #1-443 B/E - Pitts v. Freeman- Magnet Schools- DeKalb County, 1990-1991 6 8 Pitts v. Cherry- Marbut Road, 1980 6 9 B/E - Pitts- Miscellaneous, Volume II, 1969-1984 6 10 B/E- Pitts, Unitary Status- Newspaper Articles and Magazine Articles, 1989-1991 6 11 B/E- Pitts v. Freeman 1975-76 Hearings- Affidavits, 1975-1976 6 12 B/E- Pitts v. freeman 1975-76 Hearings, Correspondence, Attorney Notes, 1975-1976 6 13 Pitts v. Cherry- Deposition of Mr. William S. Adams and Mr. James J. Renfroe, 1976
Adams was Assistant Superintendent for Planning and Development for the DeKalb County School Board and the deposition focuses on how they made changes to school attendance boundaries. Renfroe was Associate Superintendent for Community and Staff Relations 6 14 Pitts v. Cherry- Exhibits, 1974-1976 6 15 1975-76 Hearings- Exhibits, Percentage Blacks, 1976 6 16 B/E- Pitts v. Freeman 1975-76 Hearings, Johnson, Intervention Motion, 1978 6 17 Pitts v. Cherry 1974 Maps, 1974 6 18 B/E- Pitts v. Freeman 1975-76 Hearings, Orders, 1976-1977 6 19 B/E- Pitts v. Freeman 1975-76 Hearings, Singleton Opinion Letters, 1978 6 20 Open Records Act, Documents Given to Roger Mills, 1988 6 21 Important Desegregation Decisions and Statutes Volume I, undated 6 22 Important Desegregation Decisions and Statutes Volume II, undated 6 23 Pitts v. Cherry- Research, 1989 6 24 B/E- Pitts- Research Brown v. B/E, 4/8/87 Memo. Opinion, 1987 6 25 DeKalb County Board of Education (Pitts v. Cherry- ESAA Research), 1975-1983 6 26 #1-443 B/E - Pitts v. Freeman- Pupil Expenditures, 1989-1990 box folder Request box R.7 1 B/E- Pitts (Research) Georgia State Conference NAACP v. State of Georgia, 1985 R.7 2 B/E Pitts v. Cherry/ Research- Memorandum Opinion, 1984 R.7 3 DeKalb County School System- Plan of Implementation for Balanced Staffing, 1989 R.7 4 #1-443 B/E - Pitts v. Freeman- Staff- Administrative and Teaching, 1989-1990 R.7 5 B/E - Pitts v. Freeman- Statements, 1989 Forward, 1989-1991 R.7 6 B/E Pitts- Singleton Compliance- Administrators, 1988 R.7 7 DeKalb County Board of Education (Pitts v. Cherry- Singleton Opinion Letters, etc.), 1978-1986 R.7 8 B/E- Pitts v. Freeman- Statements, 1986-1988 R.7 9 B/E- Pitts v. Freeman- Statements and Time Slips, OLD, 1976-1984 R.7 10 B/E Pitts v. Cherry- Memorandum 7/7/80- Summary of Case, 1980 July 7 R.7 11 B/E- Pitts v. Freeman- Research, 1970-1972 R.7 12 B/E- Pitts v. Freeman-Tipping Point Motion 1/79, Correspondence and Notes, 1979 R.7 13 Pitts v. Cherry- Exhibits, 1979 Unitary Status box folder Request box R.7 14 Area of Inquiry, Data, 1986-1987 R.7 15 Area of Inquiry, Faculty, 1986-1987 Data fields are Name of College, Race of Recruiter, Number of Applicants Seen, Race, Transfer Requests, Graded, Not Graded, SSN, DeKalb Last Name, Gwinnett Last Name, First Name, Middle Initial, Termination Date This folder must be reviewed for social security numbers prior to research use. Please request this box 3 business days prior to your research visit to allow time for this review. box folder Request box R.51 1 Area of Inquiry, Faculty, 1987 Data fields are Last Name, First Name, SSN, Race This folder contains a large number of social security numbers and is currently restricted. box folder Request box R.7 20 Area of Inquiry, Faculty, 1977-1987 Data fields are Student Composition, Average Percent of Black Faculty, Project Concert Participants, Control Group, Years Experience, Annual Salary, Certification Level, Name of School, Percent Black, Percent Teachers with Graduate Degrees, Year Resigned, Area of Inquiry, Quality of Education box folder Request box R.7 16 Dropout Information, 1979-1986 R.7 17 Expenditures per Pupil, 1986-1989 R.7 18 Free and Reduced Lunch Application, 1982-1987 R.7 19 Gains Analysis, Geoff. Berlin, 1987 R.7 21 Gains Analysis, Geoff. Berlin, 1987 R.7 22 General, 1986-1987 R.7 23 Huberty Study, 1985-1986 (UGA), 1985-1986 box folder Request box 8 1 Huberty Study, 1986-1987 (UGA), 1986-1987 8 2 Huberty Study, M-to-M Achievement, 1987 8 3 Huberty Study, Student Mobility, 1987 8 4 Materials from Vivian McMillan for Huberty Correlation Study, 1986 8 5 Summaries of Huberty's Report, 1987 8 6 Iowa Tests, 1987 8 7 Library Issue, F. Winstead Documents, 1986-1987 item Request item UC RBRL056-CS_0006 Session 82-5: SACS 1986 "A Place Called School" - John L. Goodlad, 1986 item Request item UC RBRL056-CS_0007 Session 82-1: SACS 1986 SACS First General Session - Dr. John Goodlad, 1986 box folder Request box 8 8 McMillan Exhibits Tendered, 1986-1987 Data fields are Percentiles, Pretest, Posttest, Yes to M-to-M, No to M-to-M, Black Students Complete Composite, Grade Equivalents, Black Predicted, Black Obtained, White Predicted, Grades, Percentile Gains, Free and Reduced Lunch, Dwelling 8 9 McMillan Exhibits Not Tendered, 1985-1986 Data fields are Percentiles, Mathematics-Concepts and Applications, Percentile Gains, Dwelling, Black Students, White Students, Verbal and Math, Free and Reduced Lunch, Parent and/or Guardian Title 8 10 McMillan, Other Materials, 1985-1987 Data fields are Number and Percent of Students in Specific Dwellings, NCE's Converted to Percentiles, Present Enroll, Entries, School, Grade, Black Students, White Students, Number of Matched Students, First Test Date, Second Test Date, Difference, Classr 8 11 Pre/Post Test Analysis, Without PreTest, Berlin, 1987 Data fields are PreTest and Posttest Score Analysts, School, Grade, Black Free Lunch, Black Reduced Lunch, Black Students, White Students, Black Teachers, White Teachers, Turnover, Experience, Master, Special, School ID 8 12 SACS Reports of Various Schools, 1983-1986 Additional ten-year/five-year high school studies from Southern Association of Colleges and Schools. 8 13 School Climate, Leadership Profile, 1987 8 14 School Resources, Adopt a School, 1984-1987 8 15 School Resources, 1987 item Request item UC RBRL056-CS_0001 Goodlad, undated box folder Request box 8 16 Socioeconomic Status (SES), 1985 8 17 Test Exhibits, 1984-1987 Data fields are National, DeKalb, Verbal, Math, Total, System, Race, Grade 8 18 Testing Data Not Used and Computer Runs Not Used, 1986-1987 Data fields are Iowa Test of Basic Skills, Black, White, Other, Grade 8 19 Null Tucker, 1986-1987 Data fields are Dropout Summary, Age, Sex, Year, Gender box folder Request box 9 1 Uniform Curricula, General, 1987 9 2 Uniform Curricula, Courses Not Dunwoody, 1985-1987 9 3 Witnesses, circa 1985 9 4 Walberg Study 1985-1986 (DeKalb County), 1985-1986 Statistical reports on test scores. 9 5 Walberg Study 1986-1987 (DeKalb County), 1986-1987 Statistical reports on test scores. 9 6 Area of Inquiry, Staff- General, 1985-1987 Includes the racial makeup of students and administrators at each school. 9 7 Area of Inquiry, Staff- Staff Development- Zubay, 1986-1987 Area of Inquiry, Student Assignment box folder Request box 9 8 Boundary Line Changes, 1985-1987 9 9 General, 1986-1987 9 10 Historic Attendance Data, pre-1969, 1966-1985 Data fields are Enrollments, Resident and Non-Resident, White, Black, Instructional Staff, Number of Teacher, 9 11 Historic Attendance Data, 1971-1976 Data fields are School, Year, White, Black, Other, Total box folder Request box 10 1 Junior High Information, 1984-1987 10 2 M-to-M Data, 1986-1988 10 3 AV 10 3 Magnet School Information, 1981-1987 item Request item UC RBRL056-CS_0008 Seattle Magnet Information, undated item Request item UC RBRL056-CS_0009 Seattle Magnet Information, undated box folder Request box 10 4 Private Schools, 1987 10 5 Racial Incidents, 1987 10 6 Survey Documents, 1986 10 7 Terry Mill, 1987 10 8 Area of Inquiry, Transportation, 1986-1987 10 9 Area of Inquiry, Transportation- Bus Schedules, M-to-M, 1986-1987 10 10 Area of Inquiry, Transportation- Bus Schedules, Regular, 1986-1987 10 11 DeKalb County Board of Education (Armour v. Nix- Trial Briefs), 1976-1979 10 12 Armour v. Nix Documents Re: Unitary Status and Demographics, 1975-1977 10 13 Pitts v. Freeman- Unitary Status Notes, 1986-1987 Attorney's Notes box folder Request box 10 14 S. Hawkins, Post-Trial, 1989 box folder Request box 11 1 G. Sams, 1987-1990 11 2 C. Weatherly, Post-Trial, 1990 11 3 C. Weatherly, 1986-1987 11 4 C. Weatherly from Unitary Status Hearing and from OMNI Conferences, 1987 11 5 Personal, 1982-1988 11 6 Mark Welsh, Post-Trial, 1987-1990 11 7 Mark Welsh, 1986-1987 11 8 Mark Welsh, Trial and Omni, circa 1987 11 9 Other People and Miscellaneous, 1986-1987 11 10 Other People, Miscellaneous, Trial and Omni, circa 1986 11 11 Other People and Miscellaneous- Post Trial, 1988-1989 11 12 Biracial Committee Information, 1980-1983 11 13 Charts, 1986 11 14 Cincinnati, Ohio Settlement Agreement, 1983 11 15 Columbus, Ohio Desegregation Plan, 1985-1987 11 16 Findings of Fact Headings (Computer), undated box folder Request box R.29 13 Correspondence, 1989 This folder contains restricted attorney-client privileged records and is open for research on January 1, 2040. R.29 14 Correspondence, 1988 This folder contains restricted attorney-client privileged records and is open for research on January 1, 2039. R.29 15 Correspondence, 1987 This folder contains restricted attorney-client privileged records and is open for research on January 1, 2038. R.29 16 Correspondence, 1984-1986 This folder contains restricted attorney-client privileged records and is open for research on January 1, 2037. Pitts v. Freeman Depositions box folder Request box 11 17 Doctor William Clark, 1986 Clark was Professor of Geography at U.C.L.A. in Los Angeles with a specialty in Urban and Population Geography. 11 18 Steven Cole, 1987 Cole was co-owner of Research Design Associates and taught at Emory. The deposition focuses on statistical analysis the company did for the case on test score differentials. box folder Request box 12 1 David Armor, 1986 Armor was principal Deputy Assistant Secretary for the Force Management and Personnel division at the Department of Defense. The deposition focuses on his consulting work for the DeKalb School Board on desegregation policies. 12 2 Steven Cole, 1987 Cole was co-owner of Research Design Associates and taught at Emory. The deposition focuses on statistical analysis the company did for the case on test score differentials. 12 3 Herbert Walberg, 1987 Walberg was an expert witness with expertise in educational psychology and factors that affect quality of learning. 12 4 Cynthia Scott, 1986 Scott was one of the class representatives in the case. The deposition focuses on racial ratios that would be acceptable to Scott in different circumstances, such as student population, teachers, principals, and extra curricular activates. 12 5 Berta Milla, 1986 Milla was one of the class representatives in the case. The deposition focuses on the race and qualifications of principals and teachers, and on her children's experience in the M-to-M program. 12 6 Major Scott, 1986 Scott was one of the class representatives in the case. The deposition focuses on the involvement of the N.A.A.C.P., his assessment of the Bob Mathis school that his child attended, and opinions on how appropriate ratios of race in the student population 12 7 Dr. Bill Strain, 1986 Strain was Associate Superintendent for Administration. The deposition focuses on the administration of the M-to-M Transfer Program. 12 8 Pitts v. Freeman- Continued Deposition of Herbert Walberg, 1987 Walberg was an expert witness with expertise in educational psychology and factors that affect quality of learning. The deposition focuses on new research Walberg had done since the last deposition, including statistical analysis and interviews with staff 12 9 Robert Dentler, 1987 Dentler was Professor of Sociology at the University of Massachusetts in Boston. The deposition focuses on methods for integrating school systems. 12 10 Pitts v. Freeman- Continued Deposition of Robert Dentler, 1987 Dentler was Professor of Sociology at the University of Massachusetts in Boston. The deposition focuses on statistical analysis about if the DeKalb County Schools remained segregated. 12 11 Doctor John Kicklighter, 1986 Kicklighter was Director of Planning and Development, responsible for student population project and evaluating changes to boundary line and attendance policies. 12 12 Robert Freeman, 1986 Freeman was Superintendent of the DeKalb County Schools. The deposition focuses on Freeman's evaluation of the school system with regard to race in many areas. The deposition was taken in response to the district moving for a declaration of unitary status 12 13 Roger Mills, 1986 Mills was a class representative. The deposition focuses on his assessment of the problems with the DeKalb County School System. 12 14 Discovery Data and Documents Produced to Plaintiffs, 1987 12 15 B/E- Pitts v. Freeman- Unitary Status- Discovery, 1986 12 16 Pitts v. Freeman- Exhibits, circa 1986 Exhibit A. Secondary Professional Staff; Exhibit B. DeKalb County School System District Leadership Personnel; Exhibit C. Allegations of Discrimination; Exhibit D. Secondary Transfers; Exhibit E. Per Pupil Expenditures; Exhibit F. Compensatory Education Programs ECIA Chapter I Comparability Report; Exhibit G. Comparison of Schools or Groups of Students Using Test Results; Exhibit H. California Achievement Test (CAT) - NCE Scores; Exhibit I. High School Enrollment by Race in 8th and 9th Grade English and Basic English; Exhibit J. Elementary School Students Who Completed Grade 7 but did not Complete the Series Levels in Reading and Mathematics by Race; Exhibit K. Number of Classrooms; the Capacity; the Current Enrollment by Race; and Projected Enrollment over the Next Three Years for Each School; Exhibit L. Capacity and Enrollment; Exhibit M. School/Handicap; Exhibit N. Number of Students by Race at Each School Who Dropped Out of School During 1984-1985 School Year; Exhibit O. Number of Students by Race at Each School Who were Retained Instead of Being Promoted During 1984-1985 School Year. box folder Request box 13 1 B/E- Pitts v. Freeman- Discovery, Unitary Status, Volume II, 1986-1987 13 2 U.S. Discovery Documents Produced to Plaintiff, July, '86 Volume I, 1986 Includes data and policies regarding the M-to-M program, the Biracial Committee (especially related to Briarlake and the Singleton proposal), and staff employment and turnover. 13 3 U.S. Discovery, Documents Produced to Plaintiff, July '86 Volume II, 1986 Includes data, maps, and memos related to school capacity and room uses. 13 4 U.S. Discovery, Documents Copied by Plaintiff, 1986 Includes minutes of the Biracial Committee, studies on the M-to-M program, data on staff turnover (including the school, race, and reason for leaving), information on the magnet program, and data on school capacity and room use. 13 5 Discovery-- Documents Produced and Copied for Plaintiff, 11/86 (Kicklighter), 1986 Includes data, maps, and policies from the Planning Department related to the Peachtree-Dunwoody combination, the Gordon-Walker combination, Panola Way, and old attendance lines. 13 6 B/E- Pitts, Discovery, Documents Produced for Plaintiffs, December 1986, in Response to Plaintiff's Request to Produce and 4th Interrogatories, 1986 Data and reports from twelve studies comparing student achievement. 13 7 Discovery Documents Produced per Open Records Act, 1987 Includes data on enrollment, M-to-M seats, and the number of students in the free and reduced lunch program. 13 8 Discovery Documents Produced March 1987, Information Re: Student History Files, etc., 1987 13 9 Discovery Documents Produced 4-10-87 Copied by Plaintiffs, 1987 Includes the Elementary Instruction Handbook, data on test scores, and annual goals of the DeKalb School System. 13 10 Discovery Documents Produced 4-10-87 Not Copied by Plaintiffs, 1987 Includes data on results of Iowa Tests of Basic Skills, school brochures and handbooks, and a summary of a report by the 1984 Visiting Committee of the Southern Association of Colleges and Schools about the DeKalb County elementary schools. 13 11 Open Records Request Documents- Wilde Letter of 5-4-87, 1987 Includes data, reports, and minutes of the Biracial Committee related to the number of M-to-M students who have transferred under the program. box folder Request box 14 1 Discovery, Drafts and Source Documents, 1986 Includes data and reports related to changes in boundary lines, the race of staff in different specialties, the race of students who transferred between schools, and plans for additional school construction. 14 2 Discovery, Originals, 1986-1987 14 3 Experts, Defendants' David Armor, 1987-1990 Includes data and reports on the effects of school boundary changes. 14 4-5 Plaintiff's Exhibits, 1979-1985 Includes school policies and information, M-to-M and overall enrollment data, Biracial Committee correspondence and annual reports, memos about issues, newspaper articles about the school, data about teachers, and data about student test scores. box folder Request box 30 1 High School Attendance '85-'86 [map], circa 1986 box folder Request box 14 6 DeKalb County School System Manual, 1981 14 7 Exhibit Lists, Plaintiff and Defendants, 1965-1980 B/E - Pitts, Unitary Status Hearing box folder Request box 14 8 Defendant's Exhibit 2: DeKalb Desegregation Indices Based on Actual Enrollment Data, 1965-1986 14 9 Defendant's Exhibit 3: DeKalb School Desegregation Indices Dissimilarity Index: Elementary Schools, 1965-1986 14 10 Defendant's Exhibit 4: DeKalb School Desegregation Indices Relative Exposure Index: Elementary Schools, 1965-1986 14 11 Defendant's Exhibit 5: DeKalb School Desegregation Indices Relative Exposure Index: High Schools, 1965-1986 14 12 Defendant's Exhibit 6: Dissimilarity Index: High Schools, 1965-1986 14 13 Defendant's Exhibit 7: DeKalb Desegregation Indices Computed on School of Residence, 1977-1986 14 14 Defendant's Exhibit 9: DeKalb County Georgia School Survey, 1986 14 15 Defendant's Exhibit 10: DeKalb County Population, 1950-1985 14 16 Defendant's Exhibit 11: South DeKalb County Population, 1950-1985 14 17 Defendant's Exhibit 12: North DeKalb County Population, 1950-1985 14 18 Defendant's Exhibit 13: DeKalb County Population Change, 1960-1985 14 19 Defendant's Exhibit 14: South DeKalb County Population Change by White/Minority Status, 1960-1985 14 20 Defendant's Exhibit 15: Population in South DeKalb County (by Tract) 1970-1985, 1960-1985 14 21 Defendant's Exhibit 16: Population in South DeKalb County (by Tract) 1970-1985, 1970-1985 14 22 Defendant's Exhibit 17: Population Change in South DeKalb County (by Tract) 1970-1975 and 1975-1980, 1970-1980 14 23 Defendant's Exhibit 18: Population Change in South DeKalb County (by Tract) 1980-1985, 1980-1985 14 24 Defendant's Exhibit 19: Percent Non-White Population 1960, 1960 14 25 Defendant's Exhibit 20: Percent Non-White Population 1970, 1970 14 26 Defendant's Exhibit 21: Percent Non-White Population 1975, 1975 14 27 Defendant's Exhibit 22: Percent Non-White Population 1980, 1980 14 28 Defendant's Exhibit 23: Percent Non-White Population 1985, 1985 14 29 Defendant's Exhibit 24: The Movements of Black and White Population 1975-1980, 1975-1980 14 30 Defendant's Exhibit 25: DeKalb Elementary School Districts, 1969-1970 14 31 Defendant's Exhibit 32: DeKalb High School Districts, 1985-1986 14 32 Defendant's Exhibit 36: M-to-M Data Prepared for Dr. Bill Strain, 1977-1987 14 33 Defendant's Exhibit 37: Seats Available for M-to-M Transfers, 1987-1989 14 34-35 Defendant's Exhibit 41: Table- Teachers' and Students' Racial Percentages by School 1969-1970 and 1986-1987, 1969-1987 14 36 Defendant's Exhibit 42: Faculty by Race 1969-1986, 1969-1986 14 37 Defendant's Exhibit 43: Administrators by Race, 1980-1987 14 38 Defendant's Exhibit 44: New Faculty Hires 1982-1986, 1982-1986 14 39 Defendant's Exhibit 48: Professional Staff by School 1981-1985, 1985-1986 14 40 Defendant's Exhibit 49: Organization Chart for DeKalb County School System, 1987 14 41 Defendant's Exhibit 60: Summary of School Boundary Change Effects, 1969 to 1986, 1969-1986 14 42 Defendant's Exhibit 61: Faculty Racial Balance in the DeKalb County Schools, Fall 1986, 1986 14 43 Defendant's Exhibit 68: 1986-1987 Student Assessment Test Results Summary, 1986-1987 14 44 Defendant's Exhibit 73: DeKalb County Percent Black Student Population by Attendance Districts 1985, 1985 box folder Request box R.51 3 Defendant's Exhibit 78: Former DeKalb Teachers Employed in Gwinnett County Schools, 1987 This folder contains a large number of social security numbers and is currently restricted. box folder Request box 14 45 Defendant's Exhibit 80: Transfer Requests, 1987 box folder Request box R.15 1 Defendant Exhibit 88: Curriculum Guide English, 1985 R.15 2 Defendant Exhibit 89, 1987 Statistical analysis utilizing the race of students, race of teachers, student enrollment in free or reduced lunch, and teacher turnover. R.15 3 Defendant Exhibit 91, 1987 Statistical analysis utilizing the race of students, race of teachers, and student enrollment in free or reduced lunch. R.15 4 Defendant Exhibit 105: Iowa Test of Basic Skills - Complete Composite, 1985-1987 R.15 5 Defendant Exhibit 110: Iowa Test of Basic Skills - October 1985 Grades 2 Through 7 - Complete Composite Scores, 1985 Chart of composite scores based on parent and/or guardian title. R.15 6 Defendant Exhibit 112: Iowa Test of Basic Skills - October 1985 Grades 2 Through 7 - Complete Composite, 1985 Chart of composite scores based on dwelling type. R.15 7 Defendant Exhibit 114: Iowa Test of Basic Skills Complete Composite - Grades 2 Through 7, 1985-1987 Chart of composite scores based on if new students. R.15 8 Defendant Exhibit 115: October 1986 - Iowa Tests of Basic Skills Percentiles - Complete Composite, 1986 Chart of composite scores based on if new students. R.15 9 Defendant Exhibit 117: March 1987 Iowa Tests of Basic Skills Free and Reduced Lunch Program, 1987 Chart of composite scores based on if enrolled in the free and reduced lunch program. R.15 10 Defendant Exhibit 119: SAT Averages For Black Students, 1984-1985 R.15 11 Defendant Exhibit 127: Southern Association Visiting Committee Report, 1984 R.15 12 Defendant Exhibit 135: Course Descriptions 1987, 1987 R.15 13 Defendant Exhibit 137: California Achievement Test Kindergarten - March 1986, 1986 R.15 14 Defendant Exhibit 147: Effective Parenting Program, undated R.15 15 Defendant Exhibit 148: Lead Teacher for Student Services, undated R.15 16 Defendant Exhibit 160: Special Programs to Address Needs of Changing DeKalb, 1987 R.15 17 Defendant Exhibit 165: Parenting Program, undated R.15 18 Defendant Exhibit 171: "Above Allotment" Allocations 1986-1987 Elementary Schools, 1986-1987 R.15 19 Defendant Exhibit 179: Comparison of Desegregation Attained by the Stolee Plan and the Redan Addition M-to-M Plan, 1983 R.15 20 Defendant Exhibit 180: Comparison of Desegregation Attained by the Rainbow Plan and the Redan Addition M-to-M Plan, undated R.15 21 Defendant Exhibit 181: What Each Index Measure About an Area, undated R.15 22 Defendant Exhibit 182: Two Indexes for Measuring Black's Separation from Whites in a Group of Hypothetical Schools, undated R.15 23 Defendant Exhibit 184: [Computer Use and Instruction], 1985-1987 Data fields are Course Title, School, Number of Participants, Estimate of Cost R.15 24 Defendant Exhibit 185: Projected Resident Enrollments Junior-Senior High Combinations, 1986-1989 R.15 25 Defendant Exhibit 192: Curriculum VITA Christine H. Rossell, 1987 R.15 26 Defendant Exhibit 193: Historic Attendance Data 1954-1968, 1954-1968 R.15 27 Defendant Exhibit 194: "Above Allotment" Allocations - 1986-1987 High Schools, undated R.15 28 Defendant Exhibit 212: Description of Integrated Experience Programs, undated R.15 29 Defendant Exhibit 216: DeKalb County School System Racial Percentages and Per-Pupil Expenditures, 1970-1987 R.15 30 Defendant Exhibit 217: [Survey Response Data and Results], undated R.15 31 Defendant Exhibit 221: Basic Curriculum Content for Georgia's Public School, 1985 R.15 32 Defendant Exhibit 222: Percent Black and Other Student Population by Attendance Districts, undated R.15 33 Defendant Exhibit 230: Iowa Tests of Basic Skills & Cognitive Abilities Test October 1986, 1986 R.15 34 Defendant Exhibit 233: DeKalb County Median Housing Values, 1980, 1987 R.15 35 Defendant Exhibit 234: Iowa Tests of Basic Skills October 1986 and March 1987, 1986-1987 R.15 36 Defendant Exhibit 235: Iowa Test of Basic Skills - Complete Composite Percentiles - Matched Students - Grades 2 Through 7, 1987 R.15 37-43 Faculty Exhibits 4-13, 1976-1985 Includes data on faculty education levels and memos, recruitment drives, early hiring initiatives, and race. Folder 42 must be reviewed for social security numbers prior to research use. Please request this box 3 business days prior to your research visit to allow time for this review. R.15 44 DeKalb County School System Manual, 1981 R.15 45-65 Faculty Exhibits 14-34, 1976-1985 Majority are Federal Compliance Reports on the race of faculty. Student Assignments box folder Request box R.15 66 Exhibit 1:Relative Exposure Index: Elementary Schools, 1965-1986, 1986 R.15 67 Exhibit 2: Dissimilarity Index, Elementary Schools, 1965-1986, 1986 R.15 68 Exhibit 3: Relative Exposure Index - High Schools, 1965-1986, 1986 R.15 69 Exhibit 4: Dissimilarity Index - High Schools, 1965-1986, 1986 R.15 70 Exhibit 5: DeKalb Desegregation Indexes, 1965-1986, 1986 R.15 71 Exhibit 6: DeKalb Segregation Indices Computed on School of Residence, 1984-1986, 1986 R.15 72 Exhibit 7: Indigenous Population Projections For Redan Elementary School, Fairington Elementary School, and Stone View Elementary School, 1986 R.15 73 Exhibit 9: Magnet School Preference Survey Results, 1986 R.15 74 Exhibit 12: Research for Teacher Intervention, 1986 box folder Request box 16 1 Exhibit 44: Federal Compliance Report 1972, Students - Actual Enrollment, 1972 16 2 Exhibit 25: Elementary School Boundaries, 1969-1970 16 3 Exhibit 26: Elementary School Boundaries, 1975-1976 16 4 Exhibit 27: Elementary School Districts, 1979-1980 16 5 Exhibit 28: Elementary School Boundaries, 1985-1986 16 6 Exhibit 29: High School Boundaries, 1969-1970 16 7 Exhibit 30: High School Boundaries, 1975-1976 16 8 Exhibit 31: High School Boundaries, 1979-1980 16 9 Exhibit 32: High School Boundaries, 1985-1986 16 10 Exhibit 33: Letter from Don Edwards, 1984 16 11 Exhibit 34: Students Enrolled in Majority to Minority Programs, 1977-1986 16 12 Exhibit 35: William A.V. Clark - Vita and Bibliography, undated 16 13 Exhibit 36: David J. Armor - Resume and Publications, 1986 16 14 Exhibit 37: Summary of Effects of School Boundary Changes, 1969-1986 16 15 Exhibit 38: Majority to Minority Rules and Regulations, 1980-1988 16 16 Exhibit 39: Projected Seats Available for Majority to Minority Students, 1987-1989 16 17 Exhibit 40: City of Atlanta - Percent Non-White Population, 1960 16 18 Exhibit 41: City of Atlanta - Percent Non-White Population, 1970 16 19 Exhibit 42: City of Atlanta - Percent Non-White Population, 1975 16 20 Exhibit 66: DeKalb County Population Totals and Change, 1950-1985 16 21 Exhibit 59: Percent Black Students by Attendance Zone, 1970-1971 16 22 Exhibit 60: Percent Black Students by Attendance Zone, 1975-1976 16 23 Exhibit 61: Percent Elementary Black Students by Attendance Zone, 1980-1981 16 24 Exhibit 62: Percent Elementary Black Students by Attendance Zone, 1985-1986 16 25 Exhibit 63: Private and Parochial Schools, DeKalb County, Enrollments [1971-1987], circa 1987 16 26 Exhibit 64: What Each Index Measures About an Area, undated 16 27 Exhibit 65: Two Indexes for Measuring Blacks' Separation from Whites in a Group of Hypothetical Schools, undated 16 28 Exhibit 66: DeKalb Residential Segregation Indices, 1970-1980 16 29 Exhibit 67: Projected Resident Enrollments - Junior-Senior High School Combinations, 1987-1989 16 30 Exhibit 68: Components of Desegregation Attained by the Stolee Plan and the Redan Addition M-to-M Plan, 1983 16 31 Exhibit 69: Comparison of Desegregation Attained by the Rainbow Plan and the Redan Addition M-to-M Plan, undated 16 32 Exhibit 71: Magnet Schools Preference Survey Results Summary, undated 16 33 Exhibit 72: Internal Memorandum: M-to-M Program, 1987 16 34 Exhibit 73: Percent Elementary Non-White Students by Attendance Zone, 1970-1971 16 35 Exhibit 74: Percent Elementary Non-White Students by Attendance Zone, 1975-1976 16 36 Exhibit 75: Percent Elementary Non-White Students by Attendance Zones, 1980-1981 16 37 Exhibit 76: Percent Elementary Non-White Students by Attendance Zone, 1985-1986 16 38 Exhibit 77: Percent Elementary "Other" Students by Attendance Zone, 1986-1987 16 39 Exhibit 78: Percent Elementary Black Students by Attendance Zone, 1986-1987 16 40 Exhibit 79: High School Boundaries, 1985-1986 16 41 Exhibit 80: Elementary School Boundaries, 1986-1987 16 42 Exhibit 82: Median Housing Values, 1980 16 43 Exhibit 83: DeKalb County Land Use Maps, undated 16 44 Exhibit 45: Federal Compliance Report 1973, Students - Actual Enrollment, 1973 16 45 Exhibit 46: Federal Compliance Report 1974, Students - Actual Enrollment, 1974 16 46 Exhibit 47: Federal Compliance Report 1975, Students - Actual Enrollment, 1975 16 47 Exhibit 48: Federal Compliance Report 1976, Students - Actual Enrollment, 1976 16 48 Exhibit 49: Federal Compliance Report 1977, Students - Actual Enrollment, 1977 16 49 Exhibit 50: Federal Compliance Report 1978, Students - Actual Enrollment, 1978 box folder Request box R.17 1-8 Exhibits 51-58, 1973-1989 Federal Compliance Reports for each school in the DeKalb County School System with the number of students reported by grade (K-12 and special education) and then race (white, black, other). Quality of Education box folder Request box R.17 9 Exhibit 1: Herbert J. Walberg - Curriculum Vitae, 1978-1987 This folder must be reviewed for social security numbers prior to research use. Please request this box 3 business days prior to your research visit to allow time for this review. R.17 10 Exhibit 5: Grade Equivalencies and Percentiles of Iowa Test of Basic Skills Scores in Selected Georgia School Systems 1986-1987, 1986-1987 R.17 11 Exhibit 6: Number of Dropouts in the DeKalb School System Delineated by Area, 1980-1985 R.17 12 Exhibit 8: Georgia Public Schools State Dropout Summary, 1987 R.17 13 Exhibit 9: Teacher Performance Assessment Instruments, 1986 R.17 14 Exhibit 11: Georgia's Quality of Basic Education Act, 1987 R.17 15 Exhibit 12: Student Enrollment Data by Race from OCR Survey Sample for Fall 1986 of 67 School Systems, 1986 R.17 16 Exhibit 13: What Works, 1986 R.17 17 Exhibit 14: DeKalb School System's Dropout Rate, 1980-1986 R.17 18 Exhibit 15: Average Daily Attendance 1986-1987, 1986-1987 R.17 19 Exhibit 16: Scholastic Achievement Test Scores, DeKalb and National, 1984-1985, 1984-1985 R.17 20 Exhibit 17: Media Center Books Discarded 1978-1986, 1986 R.17 21 Exhibit 18: Expenditures from Media Allotments 1978-1986, 1986 R.17 22 Exhibit 19: Books-per-Student Requirement for SACS Standards, 1986-1987 R.17 23 Exhibit 20: Dropouts by School, 1985-1986 R.17 24 Exhibit 21: New Teacher Orientation Booklet, undated R.17 25 Exhibit 22: Quarter System Course Descriptions 1986-1987, 1986-1987 box folder Request box 18 1 Exhibits 23: Staff Development Programs Taught in Local Schools, Spring 1985 to Winter 1987, 1985-1987 18 2 Exhibit 24: Bob Mathis Elementary School, Parent-Student Handbook, 1986-1987 18 3 Exhibit 25: Bob Mathis School Honors Program, 1987 18 4 Exhibit 26: Chart of Special Programs to Meet the Needs of a Changing DeKalb, 1987 18 5 Exhibit 27: Effective Parenting Program Brochure, undated 18 6 Exhibit 28: Effective Parenting Program - Educational Contract, undated 18 7 Exhibit 29: 1986-1987 DeKalb School System's Perennial and Annual Goals, 1986-1987 18 8 Exhibit 30: Description of Lead Teacher for Student Services Program, undated 18 9 Exhibit 31: Memorandum Dated February 6, 1986 re: Homework Helpline, 1986 18 10 Exhibit 32: Adopt-A-School Activities 1985-1986 and 1986-1987, 1985-1987 18 11 Exhibit 33: Adopt-A-School Program, 1984-1985 18 12 Exhibit 34: A Study of Secondary School Dropouts in Georgia, 1985 18 13 Exhibit 35: All Data from Student Master File, 1987 18 14 Exhibit 36: Revised 1986 Kindergarten California Achievement Tests, Median Percentile Scores, 1986 18 15 Exhibit 37: Review of Dwelling Characteristics 1985-1986, 1985-1986 18 16 Exhibit 38: Review of Family Characteristics 1985-1986, 1985-1986 18 17 Exhibit 39: Review of Iowa Test of Basic Skills Scores, 1986-1987, Free and Reduced Lunch, 1986-1987 18 18 Exhibit 40: Racial Percentages and Per-Pupil Expenditures, 1970-1987 18 19 Exhibit 41: Review of Iowa Test of Basic Skills Gains, 1985-1987 18 20 Exhibit 43: SAT Scores fro 1985 Freshmen at Georgia Public Colleges, 1985 18 21 Exhibit 45: Numbers and Percentages of Students Entering Specific DeKalb Schools Since January 1, 1986, 1986 18 22 Exhibit 48: Free and Reduced Lunch Applications, 1977-1978 to 1986-1987, 1977-1987 18 23 Exhibit 49: Instructional Coordinator Surveys - High Schools, 1987 18 24 Exhibit 50: Instructional Coordinator Surveys - Elementary Schools, 1987 18 25 Exhibit 51: Profile for the Assessment of Leaders, undated 18 26 Exhibit 52: Teacher Locator, November 1986, 1986 18 27 Exhibit 53: Court, Syllabus, Selected, undated 18 28 [Exhibit #53 Syllabi- Social Studies], 1986 18 29 [Exhibit #53 Syllabi- English], 1986 18 30 [Exhibit #53 Syllabi- Math], 1986 18 31 [Exhibit #53 Syllabi- Science], 1986 18 32 [Exhibit #53 Syllabi- Social Studies], 1986 18 33 [Exhibit #53 Syllabi- English], 1986 18 34 [Exhibit #53 Syllabi- Math], 1986 18 35 [Exhibit #53 Syllabi- Science], 1986 18 36 [Exhibit #53 Syllabi- Social Studies], 1986 18 37 [Exhibit #53 Syllabi- English], 1986 18 38 [Exhibit #53 Syllabi- Math], 1986 18 39 [Exhibit #53 Syllabi- Science], 1986 18 40 Exhibit 54: Scholastic Achievement Test Mean Scores by School, undated 18 41 Exhibit 55: Library Books, 1978-1986, 1978-1986 box folder Request box 19 1 Exhibit 56: The Atlanta Public Schools 1985-1986, 1986-1987 Pupil Performance and Expenditure per Pupil, 1985-1987 19 2 Exhibit 57: Brigance K and 1 Screen Manual and Form, 1982 19 3 Exhibit 58: High School Handbook, undated 19 4 Exhibit 59: DeKalb County Curriculum Guide, 1979-1987 19 5 Exhibit 60: Super Mini Activities for Reaching the Top (SMART) and Activities for Increasing Mastery (AIM) Materials, Reading Recognition, undated 19 6 Exhibit 61: A Nation at Risk, 1983 19 7 Exhibit 62: Elementary School Handbook, undated 19 8 Exhibit 63: Lesson Plans - Planning for Excellence, undated 19 9 Exhibit 64: Program of Studies, undated 19 10 Exhibit 65: Parenting Program by School, undated 19 11 Exhibit 66: An Eighth Grade Student's Guide to High School Planning, undated 19 12 Exhibit 67: Basic Curriculum Content for Georgia Public Schools, undated 19 13 Exhibit 68: Student Handbook, 1985 19 14 Exhibit 69: Career Opportunities at Occupational Center, undated 19 15 Exhibit 70: Georgia Criterion - Referenced Tests Objectives and Assessment Characteristics for Sixth Grade Mathematics and Reading Tests, 1984 19 16 Exhibit 71: Advanced Placement Courses in DeKalb County Schools, undated 19 17 Exhibit 72: After School Care Program, undated 19 18 Exhibit 73: Human Relations Program, undated 19 19 Exhibit 75: Predicted and Actual Grade Equivalents, 1986 19 20 Exhibit 76: Total Number of Courses Taught Spring, 1986, at Tucker and Columbia, 1986 19 21 Exhibit 77: Regression Analyses (Using Different Variables) with Regard to 1985-1986 Iowa Test of Basic Skills Scores, 1985-1986 19 22 Exhibit 78: Regression Analyses (Using Different Variables) with Regard to the 1986-1987 Iowa Test of Basic Skills Scores, 1986-1987 19 23 Exhibit 80: Regression Analyses (Using Different Variables) with Regard to 1986-1987 Iowa Test of Basic Skills Gains, 1986-1987 19 24 Exhibit 81: Regression Analyses (Using Different Variables) with Regard to the 1986-1987 Iowa Test of Basic Skills Scores - Majority to Minority Students, 1987 19 25 Exhibit 82: Chart - School Resources and Expenditures, Elementary Schools, 1986-1987, 1986-1987 19 26 Exhibit 83: Chart - School Resources and Expenditures, High Schools, 1986-1987, 1986-1987 19 27 Exhibit 84: Review of Iowa Test of Basic Skills Scores 1986-1987 M-to-M Program, 1986-1987 19 28 Exhibit 85: Iowa Test of Basic Skills Scores by School, 1987 19 29 Exhibit 86: Pre-Registration Information for Rising Eighth Graders, 1987 19 30 Exhibit 87: Teacher Recommendation and Registration Sheet, 1987 19 31 Exhibit 88: Southern Association of Colleges and Schools Report, 1982-1984 19 32 Exhibit 89: Master Schedule, 1987 19 33 Exhibit 90: Homework Survey, 1986-1987 19 34 Exhibit 4: Percentage of Students in Selected Georgia School Systems Passing CRT- Reading and Math 1986-1987 Test Results, 1986-1987 19 35 Exhibit 7: Percentage of Students from Each Area that Called Homework Helpline on Three Evenings, undated 19 36 Exhibit 10: Georgia Performance-Based Teacher Assessment (TPAI) 1986-1987, 1986-1987 19 37 Exhibit 44: Brigance Test, 1986-1987, by School with Percent Black Students, Percent Free and Reduced Lunch, 1986-1987 19 38 Exhibit 46: Brigance Test, 1986-1987, Correlations, 1986-1987 19 39 Exhibit 47: Brigance Test, 1986-1987, Histogram, 1986-1987 19 40 General 1: DeKalb County Board of Education By-Laws and Policies and DeKalb County School System Administrative Procedures, undated 19 41 General 2: List of Schools by Area, undated 19 42 General 3: Vita - Robert R. Freeman, undated box folder Request box 20 1 Extracurricular Activities Exhibit 1: Deposition of Robert A. Dentler, pp. 56-61, 1987 20 2 Extracurricular Activities Exhibit 2: Memorandum re: Race and Student Activities, 1987 20 3 Facilities Exhibit 1: State Requirements - Maximum Class Size, 1986 20 4 Facilities Exhibit 2: Roof Replacements, 1980-present, 1980 20 5 Facilities Exhibit 3: Local Facilities Plan Summary, 1986-1990 20 6 Facilities Exhibit 4: Renovations, Modifications, Additions, New Schools - Funded (State, Local) F.Y. 1980-1988, 1990-1988 20 7 Facilities Exhibit 5: Renovations, Modifications, Additions, New Schools, since 1980, 1987 20 8 Facilities Exhibit 6: Renovations, Modifications, Additions, New Schools since 1980 - Graph, 1987 20 9 Transportation Exhibit 1: Majority to Minority Transportation Costs, 1977-1978 to 1985-1986, 1977-1986 20 10 Transportation Exhibit 2: Transportation Policy and Procedure, undated 20 11 Transportation Exhibit 3: Activity Buses- Schedule, 1987 20 12 Transportation Exhibit 4: Sample M-to-M Bus Schedule Information, 1986-1987 20 13 Staff Exhibit 1: Professional Staff by Race 1981-1985, 1981-1985 20 14 Staff Exhibit 5: Organization Chart for DeKalb County School System 1986, 1986 20 15 Staff Exhibit 6: Administrators by Race, 1980-1981 to 1986-1987, 1980-1987 20 16 Staff Exhibit 7: Affirmative Action Procedure for the DeKalb County School System, 1982 20 17 Staff Exhibit 8: Criteria for Use with the Profile for Assessment of Leadership, 1984-1985 20 18 Staff Exhibit 9: Annual Salaries by Race, Grade, and Title, 1987 box folder Request box 30 3 Staff Exhibit 9. Annual Salaries by Race, Grade and Title, 1987 Data fields are Years Served, Certifications, Race, Grade, Title, Annual Salary box folder Request box 20 19 DeKalb County Board of Education By-Laws and Policies, 1983-1986 20 20 Some Regression Analyses, 1987 20 21 (CW)- Armor Exhibits, Tendered, 1986 Data, reports, and charts measuring desegregation indices for DeKalb County Schools. 20 22 Experts, Defendant's, Armor Exhibits, 1986 20 23 Experts, Defendants', Other Cases, Testimonies, Vol I- ARMOR, 1984-1987 20 24 Experts, Defendants', Other Cases, Testimonies, Vol II- ARMOR, 1983-1987 20 25 [Exhibit 90] Regression Analyses (Using Different Variables) With Regard to 1985-1986 Iowa Test of Basic Skills Gains, 1985-1986 box folder Request box 21 1 Experts, Defendants', Other Cases, Testimonies, Vol II- ARMOR, 1984 21 2 Experts, Defendants', Other Cases, Testimonies, Vol III- ARMOR, 1979 21 3 Experts, Defendants', Other Cases, Testimonies, Vol IV- ARMOR, 1979-1987 21 4 Experts, Defendants', Other Cases, Testimonies, Vol V- ARMOR, 1984 box folder Request box 22 1 Experts, Defendants', Other Cases, Testimonies, Vol V- ARMOR, 1978-1987 22 2 Experts, Defendants', Other Cases, Testimonies, Vol VI- ARMOR, 1978-1987 22 3 Experts, Defendants'- William Clarke, 1985-1989 Includes studies on residential segregation and on Atlanta area transportation, enrollment numbers for nonpublic schools in Georgia, and summaries of Clarke's testimony as an expert witness. 22 4 Area of Inquiry- Student Assignment CLARK EXHIBITS, circa 1975 Maps and charts showing changes in the number of whites and minorities in DeKalb County [1970-1985]. 22 5 Experts, Defendants', Other Cases, Testimonies, Vol I- CLARK, 1978 Clark was Professor of Geography at U.C.L.A. in Los Angeles with a specialty in Urban and Population Geography. Clark's testimony focused on the demographic changes in DeKalb County over 15 years and the relationship of the demographic changes to the changes in school attendance boundaries since 1969. box folder Request box 23 1 Experts, Defendants', Other Cases, Testimonies, Vol II- CLARK, 1978-1986 Clark was Professor of Geography at U.C.L.A. in Los Angeles with a specialty in Urban and Population Geography. Clark's testimony focused on the demographic changes in DeKalb County over 15 years and the relationship of the demographic changes to the changes in school attendance boundaries since 1969. 23 2 [Experts, Defendants- Bill Hawley], 1987 Hawley was at Vanderbilt University. Hawley's studies of DeKalb County Schools analyzed student success by a number of metrics based on if they are at a primarily white, mixed race, or majority black school. 23 3 Experts, Defendants'- Carl Huberty, 1986-1987 Huberty was a professor at the University of Georgia. Huberty studied DeKalb County Schools to determine how important several factors (student achievement, school socioeconomic status, student and teacher racial composition, teacher turnover, teacher experience, and teacher degree status) were to predicting results on the Iowa Tests of Basic Skills. 23 4 Experts, Defendants, Armour v. Nix Testimony- Tony Pascal, 1978 Pascal directed research at the Rand Corporation. Pascal's testimony focused on housing patterns in the urban areas of the United States and factors which affect or cause the development of such patterns. 23 5 Experts, Defendants'- Christine Rossell, 1987 Rossell was an Associate Professor in the Center for Applied Social Sciences at Boston University. Rossell's expertise for the trial focused on magnet schools, white flight, and desegregation strategies in general. box folder Request box 24 1 Experts, Defendants', Other Cases, Testimonies Vol I- Walberg, 1984 Walberg was a Research Professor of Urban Education at the University of Chicago at Illinois. Walberg studied factors that increase academic learning or achievement and testified about the effect of desegregation on achievement. 24 2 Experts, Defendants', Other Cases, Testimonies Vol II- Walberg, 1982-1987 24 3 (CW) Walberg Exhibits Tendered, 1986-1987 24 4 Defendants', Experts Walberg Exhibits- Tendered and Not Tendered, 1987 24 5 Defendants' Expert- Herbert J. Walberg, 1987 24 6 Expert, Plaintiffs'- Steven Cole, 1985-1987 Cole was an Adjunct Professor at the Emory University School of Law. Cole provided an analysis of the teachers in DeKalb County Schools. box folder Request box 25 1 Expert, Plaintiffs'- Robert Dentler, 1983-1986 Dentler was Dean of Education and Professor of Education and Sociology at Boston University. Dentler's testimony focused on magnet schools, comparing school treatment characteristics by race, analyzing the system's responses to shifting demographics and flaws he perceived in the District's current plans for future changes. 25 2 Dentler Documents, 1980 25 3 Dentler I, 1987 25 4 Experts, Plaintiffs,', Other cases, Testimonies Vol II- Dentler, 1983-1987 25 5 Experts, Plaintiffs' Studies, 1984-1987 25 6 Experts, Plaintiffs' Student Tapes Code Descriptions, 1986-1987 25 7 Factual Charts and Information, Post Trial, 1988 Analysis of staff qualifications and analysis of per pupil expenditures. 25 8 Freeman Testimony, 1983-1987 25 9 Kindergarten, 1986-1987 25 10 Lakeside Materials, 1986-1987 box folder Request box 26 1 Memoranda, 1985-1986 26 2 [Memoranda], 1987 26 3 Memoranda, 1987-1989 26 4 Mills, Roger- Witness, 1983-1989 26 5 Miscellaneous, 1986 26 6 Office of Civil Rights Investment, 1983-1986 26 7 Panola Way, 1987 26 8 Photograph's, Film, Miscellaneous (charts, maps, etc.), 1986-1987 26 9 Plaintiffs' Cost, 1986 26 10 Public Statements, 1986 26 11 Racial Percentages by School (Singleton) [1969-1986], 1986 Data fields are Students (White, Black, Other) and Faculty (White, Black) 26 12 Racial Percentages by Year (Singleton Chart) [1969-1984], 1978-1986 Data fields are Students (White, Black, Other) and Faculty (White, Black) 26 13 Joe Renfroe Materials, 1986-1987 Data about teacher changes and expenses per pupil (1985-1986), and attendance zone changes (1970-1986) 26 14 Research Volume III, 1989-1990 26 15 [Research Volume II] box folder Request box 27 1 Research Volume I, 1986 27 2 [Research], 1964 27 3 [Research], 1976-1978 27 4 Research Disclosure, Rebuttal Witnesses, 1987 27 5 Research Discovery, Quality of Education Witnesses, 1987 27 6 Research: Newspaper Articles (RDW), 1985-1987 27 7 Responses from School System for Trial and Discovery, 1986 27 8 Sams' Current File, 1988-1989 27 9 School Notebook Backup Work, 1986 27 10 Transcript Notes of Charlie Weatherly, 1987 27 11 B/E Pitts, Attendance Areas, Agendas of Meetings Regarding Changes, 1981 27 12 Pitts v Cherry- Redan to Clarkston and Redan to Lithonia Attendance Change, 1980-1983 27 13 B/E Pitts, Attendance Areas, Attendance Area Changes by Year, Index Included Vol II, 1987-1988 27 14 Pitts v. Cherry Washington, D.C. Conference on School Desegregation, 1976 box folder Request box 28 1 [Correspondence, Court Submissions, Memoranda, DeKalb County School System Budget 1990-1991, Federal Compliance Reports, DeKalb County School System Distribution of In- School Certificated Staff], 1987-1991 item Request item UC RBRL056-CS_0002 Task Force Meeting - Mills, Armstrong, and Borowski, 1990 July 10 (
1 sound_recording(s)
) item Request item UC RBRL056-CS_0003 Task Force Meeting, 1990 July 19 (
1 sound_recording(s)
) item Request item UC RBRL056-CS_0004 Task Force Meeting - Armor, Rosell, 1990 May 8 (
1 sound_recording(s)
) item Request item UC RBRL056-CS_0005 Task Force Meeting - Mills, Borowski, Armstrong, 1990 July 10 (
1 sound_recording(s)
) box folder Request box 28 2 [Pitts v Freeman Court Submissions], 1983 28 3 [Pitts v Freeman Court Submissions], 1986 28 4 [Pitts v Freeman Court Submissions], 1986
Series II. Official Records, 1968-1996
21 box(es)
(20.25 linear feet)
Series II. Official Records includes completed documents filed with or issued by the court, such as pleadings, exhibits, briefs, and memos. These documents record the progression of the arguments and decisions in the case. In addition, common subjects include the capacity and quality of school facilities, the financial decisions of DeKalb County Schools, the M-to-M (Majority to Minority) transfer program, the quality of education, and statistics about teachers and staff. Organized by type of document. These groups of documents were mostly present in the files as they were received, but were added to by the Russell staff. This series is open for research with the following exception. Boxes with restricted materials are identified with an R before the box number. An access restriction note follows each restricted folder title with an explanation of the restriction and when the folder will be open. Folders with large numbers of social security numbers are currently restricted. box folder Request box 31 1 [Affidavits], 1991-1994 31 2-3 [Attorney's Fees], 1991-1993 31 4 [Biracial Committee], 1977-1983 Briefs box folder Request box 31 5 Pitts v. Freeman Motion for Leave to File a Brief, Brief in Support of Motion to File a Brief and Brief of Amicus Curiae Southeastern Legal Foundation, Inc., 1990 31 6 Pitts v. Freeman Appeals from the United States District Court for the Northern District of Georgia, 1989 31 7 Pitts v. Freeman Suggestion of Rehearing in Banc, 1989 31 8 Pitts v. Freeman Brief of Defendants-Appellees, Cross-Appellants, 1989 31 9 Pitts v. Freeman, 1989 31 10 Pitts v. Freeman Brief for Plaintiff/Appellants, 1989 31 11 Pitts v. Freeman Appendix to Suggestion of Rehearing in Banc, 1988 31 12 Pitts v. Freeman Report to the Court on Status of Compliance with Court of Appeals Mandate, Junior High Plans, and Bond Fund Expenditures, 1990 31 13 Pitts v. Freeman Brief of Defendants-Appellees, Cross-Appellants, 1989 31 14 Pitts v. Freeman Reply Brief of Appellees, Cross-Appellants, 1989 31 15 Pitts v. Freeman JSH Files 1987-88 Unitary Status Briefs, 1987-1988 31 16 Mills v. Freeman Reply Brief of Defendants-Appellees Cross-Appellees, 1996 31 17 Mills v. Freeman Brief of Appellants, Cross-Appellees, Mills, et al., 1995 31 18 Mills v. Freeman Brief of Appellees, Cross-Appellants, 1996 box folder Request box 32 1 Pitts v. White v. Hooker v. Freeman Brief of Defendants-Appellees Robert Freeman et al., 1989 Pitts v. Freeman Briefs and Legal Memoranda box folder Request box 32 2 A. Memorandum in Opposition to Plaintiffs' Motion for Preliminary or Permanent Injunction, 1968 October 10 32 3 B. Letter from Gary Sams to Joe Renfroe re: Swann Case and HEW's 3/31/75 letter, 1975 April 21 32 4 C. Letter from Gary Sams to James Hinson Discussing the Termination of the Emergency School Aid Act Grant, 1975 May 30 32 5 D. Defendants' Brief in Opposition to Waiver of Local Rule 717, 1976 March 16 32 6 E. Defendants' Memorandum in Opposition to Plaintiffs' Motions for Supplemental Relief and for Preliminary and Permanent Injunction, 1976 August 16 32 7 F. Brief in Support of Motion to Determine Whether Action may be Maintained as a Class Action and to Determine the Status of Movant-Plaintiffs, Monica Rocker, et al, 1976 August 16 32 8 G. Brief in Support of Motion to Quash and Motion for Protective Action, 1976 August 16 32 9 H. Defendants' Supplemental Brief Concerning Boundary Line Changes Made in School Attendance Zones, 1976 September 13 32 10 I. Defendants' Memorandum in Opposition to Plaintiffs' Motion to Alter and Amend 11/3/76 Order, 1976 November 24 32 11 J. Memorandum in Opposition to Certain Named Individuals Being Appointed to the Bi-Racial Committee, 1977 February 14 32 12 K. Memorandum in Support of Defendants' Proposed Attendance Zone Changes, re: Flat Shoals, 1977 32 13 L. Memorandum of Defendants in Response to Plaintiffs' Motion for Award of Attorneys Fees, Costs and Expenses, 1977 October 17 32 14 M. Memorandum in Support of Defendants' Motion to Defer Consideration, re: Attorneys Fees, Costs and Expenses, 1977 December 16 32 15 N. Brief of Defendants and Response to Plaintiffs' Motion to Clarify and Alter Order of 12/27/77, re: Attorneys Fees, 1978 January 18 32 16 O. Response of Defendants to Intervenor's Motion to Show Cause for Contempt and Motion to Intervene, 1978 March 13 32 17 P. Brief in Support of Motion to Change Attendance Zones, re: Heritage, 1978 32 18 Q. Memorandum from Rick Tallant to Charles Weatherly re: Singleton Faculty/Staff Assignment Ratios, 1978 May 26 32 19 R. Brief in Support of Defendants' Motion to Alter or Amend, re: Kindergarten and Special Education/M-to-M, 1978 May 30 32 20 S. Memorandum from Rick Tallant to Charles Weatherly re: School Construction Case-Law, 1978 June 21 32 21 T. Brief in Response to Plaintiffs' Motion to Amend 5/23/78 Judgment, re: Flat Shoals, 1978 June 26 32 22 U. Brief in Support of Defendants' Motion for Extension of Time, 1978 June 30 32 23 V. Defendants' Supplemental and Responsive Brief, re: Kindergarten and Special Education/M-to-M, 1978 July 12 32 24 W. Letter from Charles Weatherly to Joe Renfroe re: Faculty Assignments, Compliance with Singleton Case, 1978 August 9 32 25 X. Letter from Charles Weatherly to Joe Renfroe, Additional Information re: School System's Compliance with Singleton Case, 1978 August 29 32 26 Y. Brief in Opposition to Plaintiffs' Motion to Alter Judgment, 1978 October 3 32 27 Z. Letter from Gary Sams to James Hinson re: School System's Compliance with the Singleton Requirement, 1978 November 2 32 28 AA. Brief in Support of Motion to Alter or Amend, re: Kindergarten and Special Education/M-to-M, 1979 January 24 32 29 BB. Defendants-Appellees' Court of Appeals Brief re: Kindergarten/M-to-M Program, 1979 February 1 32 30 CC. Letter from Gary Sams to David Williamson Reviewing Case Law in Desegregation Cases Throughout the United States and Pitts v Cherry in Particular, its History and Possible Future, 1980 February 5 32 31 DD. Trial brief on behalf of Defendants re: Redan, 1984 February 9 32 32 EE. Brief in Support of Motion to Review and Disallow Costs, 1984 April 9 32 33 FF. Defendants' Brief and Opposition to Plaintiffs' Motion for Costs and Attorney's Fees, 1984 June 11 32 34 GG. Defendants-Appellees' Court of Appeals Brief re: Redan, 1984 September 19 32 35 HH. Defendants Appellees' Court of Appeals Brief in Opposition to Plaintiffs-Appellants' Motion for Stay Pending Appeal, 1984 October 4 32 36 II. Defendants-Appellees' Court of Appeals Brief re: Attorneys Fees, Lakeside, 1984 October 29 32 37 JJ. Letter from Gary Sams to Three Judges, US Court of Appeals, re: the Redan Case, to Clarify Judge O'Kelley's use of the Term "Unitary" and the Defendants' Awareness that it has not Been Declared to have Achieved "Unitary" Status, 1984 November 7 32 38 KK. Defendants-Appellees' Court of Appeals Responsive Brief to Plaintiffs' Motion for Award of Attorney's Fees, 1985 April 19 32 39 LL. Letter from Gary Sams to Judge O'Kelley Regarding the Court of Appeals' Remand of the Redan Decision to the District Court, Attorneys Notes Attached, 1985 July 12 32 40 MM. Brief in Support of Defendants' Bill of Cost, 1985 December 2 32 41 NN. Memorandum from Stan Hawkins to Gary Sams and Charlie Weatherly re: Steps Necessary to Achieve "Unitary" Status in School Desegregation Case, 1985 December 12 32 42 OO. Memorandum in Support of Motion to Dismiss, 1986 January 16 32 43 PP. Letter from Gary Sams to William Strain re: Briarcliff High School M-to-M Transfer Program, 1986 April 21 32 44 QQ -1. Defendants' Response to Motion to Compel Defendants to Answer Plaintiffs' Third Set of Interrogatories, 1986 July 28 32 45 QQ - 2. Case Notes from Mark Welsh on Faculty and Substantial Compliance with Desegregation Plans, 1986 October 13 32 46 RR. Memo from Stan Hawkins to Gary Sams, Charles Weatherly, and Mark Welsh re: U.S. Supreme Court decision, Wygant v. Jackson Board of Education., 1986 October 28 32 47 SS. Memorandum from Stan Hawkins to Gary Sams, Charlie Weatherly, and Mark Welsh re: Singleton and District Court Requirements on Faculty Assignment., 1986 November 1 32 48 TT. Defendants' Memorandum in Opposition to Plaintiffs' Motions of 11/17786, re: Discovery and Change of Counsel., 1986 November 21 32 49 UU. Memorandum from Stan Hawkins to Gary Sams, Charlie Weatherly, and Mark Welsh re: Student Assignment/Legal Theory., 1986 November 24 32 50 VV. Defendants' Reply to Plaintiffs' Motion to Require Defendants to Produce Data in Merged Form and for Reconsideration of Motion to Extend Discovery and Reschedule Hearing Date., 1986 December 4 32 51 WW. Memorandum from Mark Welsh to Gary Sams and Charlie Weatherly re: Welsh's and Hawkins' Notes on Each Area of Inquiry Involved in the "Unitary Status" Motion., 1987 February 13 32 52 XX. Memorandum from Mark Welsh to Sams, Weatherly, and Hawkins re: Discovery of Quality of Education Experts., 1987 May 14 32 53 YY. Memorandum from Mark Welsh to Sams, Weatherly, and Hawkins re: Discovery of Rebuttal Witnesses., 1987 May 19 32 54 ZZ. Memorandum from Karen Christie to Stan Hawkins re: Testimony of Dr. Vivian McMillan., 1987 June 9 32 55 AAA. Memorandum from Mark Welsh re: Terry Mill 1969 addition., 1987 June 15 32 56 BBB. Memorandum from Karen Christie to Stan Hawkins re: Doctrine of the Law of the Case., 1987 June 18 32 57 CCC. Memorandum from Julie Jennings to Charlie Weatherly re: Reliance on Learned Treatises by Expert Witnesses., 1987 July 7 32 58 DDD. Memorandum from Richard D. Winston to Gary Sams re: Admissibility of Court Testimony Based Upon Newspaper's Classified Advertising - Study of Residential Property Sales Relationship to Area School Districts., 1987 July 15 32 59 EEE. Memorandum from Karen Christie to Gary Sams and Charlie Weatherly re: Proper Scope of Surrebuttal., 1987 July 20 32 60 FFF. Defendants' Brief in Response to Plaintiffs' Motion for Supplemental Relief., 1987 August 10 32 61 GGG. Defendants' Post-Trial Brief in Support of their Motion for a Declaration of Unitary Status and for Final Dismissal., 1987 October 13 32 62 HHH. Defendants' Reply to Plaintiffs' Post-Trial Brief in Opposition to Defendants' Motion for a Declaration of Unitary Status and Final Dismissal., 1987 November 9 32 63 III. Defendants' Brief in Response to Plaintiffs' Motion to Require Defendants to File Junior High Plan., 1987 November 9 32 64 Freeman v. Pitts Brief of Petitioners, 1990 32 65 Freeman v. Pitts Brief for the United States as Amicus Curiae Supporting Petitioners, 1990 32 66 Freeman v. Pitts Brief Amicus Curiae of Plaintiff-Intervenors Seeking Reversal in Part and Affirmance in Part, 1990 32 67 Freeman v. Pitts Reply Brief of Petitioners, 1989 32 68 Freeman v. Pitts Reply Brief of Petitioners, 1991 32 69 Freeman v. Pitts Petition for a Writ of Certiorari to the United States Court of Appeals for the Eleventh Circuit, 1989 32 70 Freeman v. Pitts Respondents' Brief, 1990 32 71 Freeman v. Pitts Joint Appendix (Volume I, pp. 1-430), 1990 32 72 Freeman v. Pitts Joint Appendix (Volume II, pp. 431-872), 1990 Court Submissions
Court submissions contains various types of documents filed with the court, such as motions, memoranda of law, statements, and responses to documents filed by the opposing side. Subjects include outlining arguments for granting unitary status, clarification of facts about DeKalb County school, legal precedents from other desegregation cases, and analyzing if proposed actions by the DeKalb County Schools would promote or hinder desegregation efforts. box folder Request box 32 73 [Court Submissions], 1990 box folder Request box 33 1-5 [Court Submissions], 1987-1990 box folder Request box 34 1-4 [Court Submissions], 1975-1992 Depositions
These include depositions of parents of students enrolled in DeKalb County Schools, school board members, and expert witnesses. Subjects include their experiences as a parent, decisions made at various meetings, NAACP involvement with the case, and analysis of statistics to show if the schools have desegregated or if there is remaining racial discrimination. box folder Request box 34 5 [Depositions], 1990 box folder Request box 35 1-4 [Depositions], 1987-1990 box folder Request box 36 1 [Depositions], 1990 36 2 [Notice of Depositions], 1976, 1990 36 3 [Equitable Relief from Overcrowding], 1993 Exhibits box folder Request box 36 4-6 Exhibit 1. Georgia Public Schools Standard Number 110, 1988 Maximum Class Sizes for GBOE [Georgia Board of Education] Reports 36 7 Exhibit 2A. Georgia Board of Education Policy Code IEC, 1986 Maximum Class Size box folder Request box 37 1 Exhibit 2B. Working Version of IEC for 1990-1991 School Year, 1990-1991 Maximum Class Size box folder Request box R.51 5 Exhibit 3A. Individual School Class Size Reports - Elementary School, 1990 This folder contains a large number of social security numbers and is currently restricted. box folder Request box 37 2-5 Exhibit 3B. Individual School Class Size Reports - Special Education, 1988-1989 box folder Request box R.51 6-9 Exhibit 3C. Individual School Class Size Reports - Secondary School, 1989 These folders contain a large number of social security numbers and are currently restricted. box folder Request box 37 6 Exhibit 4. Summary Reports Submitted to Georgia Board of Education Since June 30, 1988, 1988-1990 box folder Request box 38 1 Pitts v. Freeman Defendants' Answer to Plaintiffs' Interrogatories, 1990 Pitts v. Freeman Defendants' Answer to Plaintiffs' (Second) Interrogatories box folder Request box 38 2 1. Description of Every Application Defendants have Filed for the Magnet Schools Assistance Program, or any Other Federal Programs, in the Last Six Years., undated 38 3 2. Description of Every Application for the Funds for Magnet Schools from the State of Georgia for the Last Five Years., undated 38 4 3. Description of Each Magnet School (or Program) which Defendants Currently Operate. For Each Such School (or Program), State the Number of Students, by Race, Who Attend the School (or Program)., undated 38 5 4. For Each Magnet Program Described in the Answer to Interrogatory No. 3, Description of the Interaction of All Students in Each Program with the Students of the School in which the Program is Housed., undated 38 6 5. School List, 1990 Net Capacity/Enrollment 38 7 6. [M-to-M Projections], 1990 Data fields are School Name, Black, White/Other, Total 38 8 7. Mobile Unit Location, 1985-1990 Data fields are School Name, Without Mobile Units, With Mobile Units 38 9 8. For the 1989-90 School Year, State the Number of M-to-M Students, by Race; the "Home" Schools of these Students; and the Schools to which these Students have Transferred., 1989 Data fields are Majority White Schools, Majority Black School 38 10 9. Change Tabulations, 1989-1990 38 11 10. Statement of Bond Fund Expenditures, 1990 38 12 11. Description of any Studies Completed by or for Defendants on Middle Schools and/or Junior High School. Include any Reports to the Board of Education; any Reports to the State Department of Education; any Cost Studies for Middle Schools and/Junior High, 1979-1990 38 13 12. Description of the Location of each Special Education Classroom Operated by Defendants. Include the Type of Special Education Provided, the Number of Children by Race in Each Special Education Classroom, the "Neighborhood" School of Each Child in a Sp, 1989-1990 38 14 13. Description of All Programs Provided for Students for whom English is not the Native Language. Include the Location of Each Program where such Services are Provided, the Number of Students by Race who Attend Each Location, the Length of Time of the Bu, undated Department of Elementary Instruction the English to Speakers of Other Languages Program (ESOL) 38 15 14. Transportations Question and Answer to Interrogatories, undated 38 16 15. Description of Any Changes in Student Disciplinary Rules and/or Procedures Implemented Since 1986, 1986-1987 38 17 19. What Changes have been made in Staffing since the 1986-87 School Year?, 1986-1987 38 18 20. Description of Any Changes in Curriculum Which Have Been Made Since the 1986-1987 School Year, 1986-1987 Curriculum Guides 38 19 21. [School Capacity, Funding Source, and Racial Make-Up for Salem Junior High, Panola Way Elementary, Pine Ridge Elementary, Browns Mill Elementary, and Bellingrath Elementary], undated 38 20 22. Description of the Plans for Publicizing the M-to-M Program for the 1990-91 School Year; Include a Listing of Any Schools or Programs Which Will be Closed to M-to-M and the Reasons for the Closure. Description of Any Limitations Imposed on M-to-M for, 1989-1990 38 21 Exhibit 2. DeKalb County Schools Recap of per Pupil Expenditures, 1989-1990 Data fields are School Number, School Name, ADA [Average Daily Attendance], Total Expenditures, Expenditures per Pupil 38 22 Exhibit 3. Federal Compliance Report, 1990 38 23 Exhibit 4 Parts 1-7. [Student List], 1990 Data fields are Student Number, Race, Age, Residence 38 24 Exhibit 1(a). M-to-M Transfer Regulations, 1990-1992 38 25 Exhibit 1(c)-1. Number of Active M-to-M Students by School and Grade, 1989-1990 38 26 Exhibit 1(c)-2. M-to-M Data Prepared for: Dr. Bill Strain, 1977-1987 38 27 Exhibit 2(d). Parent Questionnaire Magnet Program, undated 38 28 Exhibit 2(e). DeKalb Board of Education 1990 Citizen's Advisory Committee, 1990 box folder Request box 39 1 Exhibit 9. Human Relations Representatives Program, 1989-1991 39 2 Exhibit 10. Homework Helpline, 1988-1991 39 3 Exhibit 11(b). Interrogative 11b DeKalb Partners in Education, 1991 Data fields are School/Program, Date Partnered 39 4 Exhibit 12(a). Staff Development Comprehensive Plan, 1991-1992 39 5 Exhibit 12(f). Participant Evaluation of Staff Development Activity, undated 39 6 Exhibit 12(g). Goal Status Report, 1990-1991 Board Perennial Goals Department of Staff Development 39 7 Exhibit 13(a). Prime Time After School Child Care: Fulton, DeKalb, and Clayton County Schools and the City of Atlanta Schools/YMCA, undated 39 8 Exhibit 13(b). Prime Time Enrollment Figures Fall Quarter Report, 1990 Data fields are School Name, YMCA, YWCA, PNA 39 9 Exhibit 14(f)-1. Georgia Department of Education Chapter 1 Report of Instructional Activities, 1989-1990 Data fields are Grade, Membership, Number Tested, Average NCE Gain 39 10 Exhibit 14(d)-2. Students in State Remedial Reading Program, 1991 Data fields are School, Total, Race 39 11 Exhibit 14(f)-2. DeKalb County School System State Remedial Education Program Evaluation, 1989-1990 Data fields are Grade, Percentiles 39 12 Exhibit 14(c)-3. Remedial Education Program Resource Manual for Program Administration, 1989 39 13 Exhibit 15(b). Writing to Reading Labs, 1985-1991 39 14 Exhibit 15(d). Kindergarten Students by School, by Race, 1991 39 15 Exhibit 15(f). Writing to Reading Program Evaluation Executive Summary, 1989 39 16 Exhibit 22. DeKalb County School System Distribution of In-School Certificated Staff, 1991 Data fields are School, Type, Certified Staff, Race, Percent 39 17 Exhibit 23(a). DeKalb County School System Percentage of Staff with a Master's Degree or Higher, By Race, 1991 Data fields are School, Type, Total Staff FTE, Total Staff Master's or Higher, Total Black Staff, Total White Staff 39 18 Exhibit 23(b). DeKalb County School System Average Years Experience as Recognized by State, 1991 Data fields are School, Type, Total Staff FTE, Average Years Experience, Total Black Staff, Total White Staff 39 19 Exhibit 23(d). DeKalb County School System In-School Administrators, 1991 Data fields are School, Race of Principal 39 20 Exhibit 28. Appendix A, 1989-1991 Staff resignations, leaves, and category changes 39 21 Exhibit 29 [pt. 1]. DeKalb County School System Current Staff Analysis by Race, 1991 Data fields are Allotment Category, Race, Total box folder Request box R.51 10 Exhibit 29 [pt. 2]. DeKalb County School Professional School Book, 1991 Data fields are Position Code, Position Title, Employee Name, Staff FTE, Staff Allot This folder contains a large number of social security numbers and is currently restricted. box folder Request box 39 22 Exhibit 30(a). New Teacher Instructional Orientation, 1990 39 23 Exhibit 30(d). Georgia Department of Education Teacher Education and Staff Development Participant Evaluation of Staff Development Activity, 1990 39 24 Exhibit 32. DeKalb County School System Course Descriptions 1990 DeKalb County High Schools, 1990 39 25 Exhibit 56(a). DeKalb County School System Procedures for Due Process Related to Student Discipline, Offenses, and Student Organizations, 1990-1991 39 26 Exhibit 56(b). Student Rights and Responsibilities Code of Student Conduct for the DeKalb County School System, 1990-1991 39 27 Exhibit 57. DeKalb County School System Iowa Tests of Basic Skills Complete Composite - Mean NCE Scores, 1988-1990 Data fields are Race, Grade, Count, NCE Score 39 28 Exhibit 1(c)-1. Number of Active M-to-M Students by School and Grade, 1986-1990 Data fields are School, Race, Verbal, Math, Total 39 29 Exhibit 62(a). Promotion and Retention Criteria Policy and Procedure, 1988-1990 39 30 Exhibit 62(b). Plaintiff Johnson Interrogatory Dated March 22, 1991 - Response 62, 1988-1991 Data fields are Period, Number of Students Receiving Grades, Number of Grades 39 31 Exhibit 66(a). Dropout Prevention, 1990 39 32 Exhibit 66(b). Georgia Department of Education - Statistical Services Section Principal's Annual Report, 1990 Data fields are Card, Grade, Sex, Total Dropouts, Pupils Retained 39 33 Exhibit 58 Scholastic Aptitude Test Juniors and Seniors who Took the SAT During the October, 1993 Administration, 1995 Data fields are School, Count, Verbal, Math, Total 39 34 Exhibit 57 Interrogatory #57 For Each School, Identify the Test Results Since January, 1993, for the Iowa Tests of Basic Skills. Further, Provide Breakdown of those Scores by Race for Each School and for the System as a Whole, 1993-1994 Data fields are Test Date, NCE Score 39 35 Exhibit 56(a). Student Rights and Responsibilities Code of Conduct for the DeKalb County School System, 1994-1995 39 36 Exhibit 56(b). DeKalb County School System Administrative Procedures for Student Discipline Prepared by Department of Student Relations, 1994-1995 39 37 Exhibit 32 DeKalb County School System Robert R. Freeman, Superintendent Course Descriptions, 1992 39 38 Exhibit 30(a). 1-2 New Teacher Instructional Orientation, undated 39 39 Exhibit 30(d). Georgia Department of Education Teacher Education and Staff Development Participant Evaluation of Staff Development Activity, undated 39 40 Exhibit REP 14(d). Students in State Remedial Reading and Math Program, 1994 Data fields are School, Total, Race 39 41 Exhibit REP 14(f). DeKalb County School System State Remedial Education Program Evaluation, 1993-1994 Data fields are Math, Reading Comprehension, Grade, NCE Score 39 42 Exhibit Chapter I 14(f). Georgia Department of Education Statistical Report of Chapter 1 Program Activities, 1993-1994 39 43 Exhibit 13 A.R.T. Station, INC. Philosophy of Arts Education for Children, 1994-1995 39 44 Exhibit 11(f).(1). The DeKalb Partners in Education 11th Year Honor Roll, 1983-1994 39 45 Exhibit 11(f).(2). 1995 DeKalb Chamber of Commerce Business Desk Reference, 1995 39 46 Exhibit 11(f).(3). DeKalb Partners in Education Partners 11 Years of Excellence Volume 1, Issue 1, 1994 box folder Request box 40 1 Exhibit 9. Human Relations Representative Program Annual Survey, undated 40 2 Exhibit 1C. Number of Active M-to-M Students By School and Grade, 1991-1994 40 3 Exhibit 11(b)(1). DeKalb Partners in Education Honor Roll, 1984-1994 40 4 Exhibit 11(b)(2). Partners at Large and Collaboratives, undated 40 5 Exhibit 1(a). M-to-M Transfer Regulations for DeKalb County Schools, 1995-1996 40 6 Exhibit 12(a). Staff Development Comprehensive Plan, 1995-1996 40 7-19 [Interrogatories], 1977-1995
Includes responses to interrogatories from the plaintiffs with data about the race of students and staff, financial expenditures and bonds, test scores, decisions related to school attendance boundaries and school renovations, and lists of courses. box folder Request box 41 1-143 [Orders], 1968-1996 Pleadings box folder Request box 42 1 1. Pitts v. Cherry - Plaintiffs' Memorandum of Points and Authorities on Majority to Minority Transfer Provisions, undated 42 2 2. Pitts v. Cherry - Plaintiffs' Proposed Order Majority to Minority Transfers, undated 42 3 3. Pitts v. Cherry - Defendants' Proposed Order Regarding Majority-to-Minority Transfer, undated 42 4 4. Pitts v. Cherry - Complaint, 1968 42 5 5. Pitts v. Cherry - Answer, 1968 42 6 6. Pitts v. Cherry - Motion for Preliminary Injunction, undated 42 7 7. Pitts v. Cherry - Memorandum in Support of Plaintiffs' Motion for Preliminary or Permanent Injunction, undated 42 8 8. Pitts v. Cherry - Memorandum in Opposition to Plaintiffs' Motion for Preliminary or Permanent Injunction, 1968 42 9 9. Pitts v. Cherry - Summary of Questions Civil Rights Suit, 1968 42 10 10. Pitts v. Cherry - Motion for Preliminary or Permanent Injunction, undated 42 11 11. Pitts v. Cherry - Brief in Support of Motion for Preliminary or Permanent Injunction, 1975 42 12 12. Pitts v. Cherry - Motion for Supplemental Relief, undated 42 13 13. Pitts v. Cherry - Brief in Support of Motion to Waive Application of Local Rule 71.7 and to Permit the Withdrawal of Howard Moore, Jr., and Elizabeth Rindskopf, as Counsel of Record for Plaintiffs, 1976 42 14 14. Pitts v. Cherry - Defendants' Brief in Opposition to Waiver of Local Rule 71.7, 1976 42 15 15. Pitts v. Cherry - Plaintiffs' Memorandum of Issues Remaining for Court Resolution, 1976 42 16 16. Pitts v. Cherry - Defendants Memorandum of Issues to be Resolved, 1976 42 17 17. Pitts v. Cherry - Notice, 1976 42 18 18. Pitts v. Cherry - Deposition Subpoena to Produce Documents and Things, 1976 42 19 19. Pitts v. Cherry - Objections to Movant's Request for Production of Documents, 1976 42 20 20. Pitts v. Cherry - Defendants' Memorandum in Opposition to Plaintiffs' Motions for Supplemental Relief and for Preliminary or Permanent Injunction, 1976 42 21 21. Pitts v. Cherry - Motion to Determine Whether Action May Be Maintained as a Class Action and to Determine The Status of the Movant- Plaintiffs, Monica Rocker, et al., 1976 42 22 22. Pitts v. Cherry - Brief in Support of Motion to Determine Whether Action May be Maintained as a Class Action and to Determine the Status of the Movant- Plaintiffs, Monica Rocker, et al., 1976 42 23 23. Pitts v. Cherry - Motion to Quash and Motion for Protective Order, 1976 42 24 24. Pitts v. Cherry - Brief in Support of Motion to Quash and Motion for Protective Action, 1976 42 25 25. Pitts v. Cherry - Defendant's Supplemental Brief Concerning Boundary Line Changes Made in School Attendance Zones, 1976 42 26 26. Pitts v. Cherry - Brief in Opposition to Plaintiffs Motion to Alter Judgement, 1976 42 27 27. Pitts v. Cherry - Objection to Substitution of Parties, 1976 42 28 28. Pitts v. Cherry - Motion to Substitute Parties, 1976 42 29 29. Pitts v. Cherry - Plaintiffs' Motion to Alter and Amend Order, 1976 42 30 30. Pitts v. Cherry - Defendants' Memorandum in Opposition to Plaintiffs' Motion to Alter and Amend November 3, 1976 Order, 1976 42 31 31. Pitts v. Cherry - Plaintiffs' Selection of Members to the Bi-Racial Committee, 1977 42 32 32. Pitts v. Cherry - Defendants' Nomination of Members to the Bi-Racial Committee, 1977 42 33 33. Pitts v. Cherry - Memorandum in Opposition to Certain Named Individuals Being Appointed to the Bi-Racial Committee, 1977 42 34 34. Pitts v. Cherry - Plaintiffs' Memorandum in Response to Defendants' Objections to Certain of Plaintiffs' Nominees to the Bi-Racial Committee, 1977 42 35 35. Pitts v. Cherry - Motion to Alter or Amend Order Dated March 29, 1977, 1977 42 36 36. Pitts v. Cherry - Plaintiffs' Response to Defendants' Motion to Alter or Amend Order Dated March 29, 1977, 1977 42 37 37. Pitts v. Cherry - Plaintiffs' Proposed Order for Bi-Racial Committee Guidelines, 1977 42 38 38. Pitts v. Cherry - Plaintiffs' Motion for Award of Attorneys' Fees, Costs and Expenses, 1977 42 39 39. Pitts v. Cherry - Defendants' Proposed Procedural Guideline, 1977 42 40 40. Pitts v. Cherry - Plaintiff's Supplemental Motion for Award of Attorneys' Fees, Costs, and Expenses, 1977 42 41 41. Pitts v. Cherry - Plaintiffs' Memorandum to the Court, 1977 42 42 42. Pitts v. Cherry - Memorandum in Support of Defendants Proposed Attendance Zone Changes, 1977 42 43 43. Pitts v. Cherry - Memorandum of Defendants in Response to Plaintiffs Motion for Award of Attorneys Fees, Costs and Expenses, 1977 42 44 44. Pitts v. Cherry - Stipulation for Extension of Time, 1977 42 45 45. Pitts v. Cherry - Plaintiffs' Brief in Reply to Defendants' Memorandum in Opposition for an Award of Attorneys' Fees, Costs and Expenses, 1977 42 46 46. Pitts v. Cherry - Defendants Interrogatories and Request for Production of Documents to Plaintiffs, 1977 42 47 47. Pitts v. Cherry - Plaintiffs' Motion for Protective Order, 1977 42 48 48. Pitts v. Cherry - Motion to Defer Consideration, 1977 42 49 49. Pitts v. Cherry - Additional Response of Co- Counsel to Plaintiffs' Motion for Protective Order, 1977 42 50 50. Pitts v. Cherry - Plaintiffs' Motion to Clarify and Alter Order of December 27, 1977, 1978 42 51 51. Pitts v. Cherry - Brief of Defendants and Response to Plaintiffs Motion to Clarify and Alter Order of December 27, 1977, 1978 42 52 52. Pitts v. Cherry - Motion to Intervene as a Plaintiff, 1978 42 53 53. Pitts v. Cherry - Motion for Rule to Show Cause for Contempt, 1978 42 54 54. Pitts v. Cherry - Amendment to Plaintiff Ann Trippe Johnson's Brief in Support of Motion to Show Cause Why Defendants Should Not be Held in Contempt, 1978 42 55 55. Pitts v. Cherry - Response of Plaintiffs to Motion to Intervene and Motion for Rule to Show Cause for Contempt, 1978 42 56 56. Pitts v. Cherry - Stipulation for Extension of Time, 1978 42 57 57. Pitts v. Cherry - Response of Defendant to Intervenor's Motion to Show Cause for Contempt and Motion to Intervene, 1978 42 58 58. Pitts v. Cherry - Plaintiffs' Motion for Supplemental Relief, 1978 42 59 59. Pitts v. Cherry - Brief in Support of Plaintiffs' Motion for Supplemental Relief, 1978 42 60 60. Pitts v. Cherry - Motion to Allow Defendants to Change Attendance Zones, 1978 42 61 61. Pitts v. Cherry - Brief in Support of Motion to Change Attendance Zones, 1978 42 62 62. Pitts v. Cherry - Defendants Motion to Alter and Amend Order, 1978 42 63 63. Pitts v. Cherry - Brief in Support of Defendants Motion to Alter or Amend, 1978 42 64 64. Pitts v. Cherry - Motion to Amend Judgement, 1978 42 65 65. Pitts v. Cherry - Brief in Support of Motion, 1978 42 66 66. Pitts v. Cherry - Supplement to Brief in Support of Motion, 1978 42 67 67. Pitts v. Cherry - Plaintiffs' Response to Defendants' Motion to Alter or Amend Order of November 3, 1976, 1978 42 68 68. Pitts v. Cherry - Stipulation for Extension of Time, 1978 42 69 69. Pitts v. Cherry - Stipulation for Extension of Time, 1978 42 70 70. Pitts v. Cherry - Brief in Response to Plaintiffs Motion to Amend Judgment, 1978 42 71 71. Pitts v. Cherry - Motion for Extension of Time, 1978 42 72 72. Pitts v. Cherry - Brief in Support of Defendants Motion for Extension of Time, 1978 42 73 73. Pitts v. Cherry - Defendants Supplemental and Responsive Brief, 1978 42 74 74. Pitts v. Cherry - Plaintiffs Response to Defendants Supplemental Brief, 1978 42 75 75. Pitts v. Cherry - Motion to Alter Judgment, 1978 42 76 76. Pitts v. Cherry - Brief in Opposition to Plaintiffs Motion to Alter Judgment, 1978 42 77 77. Pitts v. Cherry - Notice of Appeal, 1978 42 78 78. Pitts v. Cherry - Stipulation Waiving Bond for Costs on Appeal, 1978 42 79 79. Pitts v. Cherry - Designation of Portion of Record and Statement of Issues on Appeal, 1978 42 80 80. Pitts v. Cherry - Motion for Summary Reversal and Brief for Plaintiffs- Appellants, 1979 42 81 81. Pitts v. Cherry - Defendants' Motion to Alter and Amend Order, 1979 42 82 82. Pitts v. Cherry - Stipulation to Supplement Record, 1979 42 83 83. Pitts v. Cherry - Plaintiffs' Response to Defendants' Motion, 1979 42 84 84. Pitts v. Cherry - Brief for Defendants- Appellees, 1979 42 85 85. Pitts v. Cherry - Motion to Alter or Amend Order Dated March 29, 1977, 1979 42 86 86. Pitts v. Cherry - Plaintiffs' Motion to Defendants' Motion to Replace Bi-Racial Committee Member, 1979 42 87 87. Pitts v. Cherry - Notice of Withdrawal, 1979 42 88 88. Pitts v. Cherry - Plaintiffs' Nominations to Bi-Racial Committee and Response to Defendants' Nominations, 1982 42 89 89. Pitts v. Cherry - Plaintiffs' Response to Bi-Racial Committee Vacancies, 1983 42 90 90. Pitts v. Cherry - Report to Court as to Change of Attendance Zones, 1983 42 91 91. Pitts v. Cherry - Motion for Preliminary Injunction and Motion for Supplemental Relief, 1983 42 92 92. Pitts v. Cherry - Suggestion for Substitution of Parties, 1983 42 93 93. Motion for Leave of Absence, 1983 42 94 94. Pitts v. Freeman - Plaintiffs' Interrogatories to Defendants, 1983 42 95 95. Pitts v. Freeman - Order, 1990 42 96 96. Pitts v. Freeman - Motion for Leave to Intervene, 1984 42 97 97. Pitts v. Freeman - Pitts v. Freeman, 1984 42 98 98. Pitts v. Cherry - Motion to Intervene as a Plaintiff, 1984 42 99 99. Pitts v. Cherry - Brief in Support of Motion to Intervene, undated 42 100 100. Pitts v. Cherry - Complaint by Intervenors, 1984 42 101 101. Pitts v. Freeman - Motion for Expedited Hearing, 1984 42 102 102. Pitts v. Freeman - Trial Brief on Behalf of Defendants, 1984 42 103 103. Pitts v. Freeman - Notice of Appeal, 1984 42 104 104. Pitts v. Cherry - Bill of Costs, 1984 42 105 105. Pitts v. Freeman - Motion to Review and Disallow Costs, 1984 42 106 106. Pitts v. Freeman - Plaintiffs' Withdrawal of a Duplicate Notice of Appeal, 1984 42 107 107. Pitts v. Freeman - Plaintiffs' Withdrawal of Bill Costs, 1984 42 108 108. Pitts v. Freeman - Stipulated Statement of the Proceedings to Supplement the Record on Appeal, 1984 42 109 109. Pitts v. Freeman - Plaintiffs' Motion for an Award of Fees and Costs, 1984 42 110 110. Pitts v. Freeman - Defendant's Brief and Opposition to Plaintiff's Motion for Cost and Attorney Fees, 1984 42 111 111. Pitts v. Freeman - Plaintiffs' Supplemental Memorandum in Support of Motion for Attorneys' Fees and Costs, 1984 42 112 112. Pitts v. Freeman - Brief for Plaintiffs and Appellants, 1984 42 113 113. Pitts v. Freeman - Motion for Extension of Time for Filing of Appellees' Brief, 1984 42 114 114. Pitts v. Freeman - Notice of Appeal, 1984 42 115 115. Pitts v. Freeman - On Appeal from the United States District Court for the Northern District of Georgia, 1984 42 116 116. Pitts v. Freeman - Brief for Plaintiffs- Appellants, 1984 42 117 117. Pitts v. Freeman - Record Excerpts, 1984 42 118 118. Pitts v. Freeman - Motion for Injunction Pending Appeal, 1984 42 119 119. Pitts v. Freeman - Motion for Injunction Pending Appeal and for Expedited Disposition, 1984 42 120 120. Pitts v. Freeman - Defendants- Appellees Brief in Opposition to Plaintiffs- Appellants Motion for Stay Pending Appeal, 1984 42 121 121. Pitts v. Freeman - Reply Brief, 1984 42 122 122. Pitts v. Freeman - Brief of Defendants- Appellees, 1984 42 123 123. Pitts v. Freeman - Joint Supplemental Submission of Appellants and Appellees, 1984 42 124 124. Pitts v. Freeman - Reply Brief for Appellants, 1984 42 125 125. Pitts v. Freeman - Motion for Award of Attorney's Fees, 1984 42 126 126. Pitts v. Freeman - Brief of Defendants- Appellees, 1985 42 127 127. Pitts v. Freeman - Bill of Costs, 1985 42 128 128. Pitts v. Freeman - Motion for Final Dismissal, 1985 42 129 129. Pitts v. Freeman - Stipulation for Extension of Time for Plaintiffs to File Response to Defendants' Motion for Final Dismissal, 1986 42 130 130. Pitts v. Freeman - Plaintiffs' Response to Motion for Final Dismissal, 1986 42 131 131. Pitts v. Freeman - Plaintiffs' First Set of Interrogatories, 1986 42 132 132. Pitts v. Freeman - Defendants' Interrogatories to Plaintiffs, 1986 42 133 133. Pitts v. Freeman - Defendants Answers and Responses to Plaintiffs First Set of Interrogatories, 1986 42 134 134. Pitts v. Freeman - Defendants Second Interrogatories to Plaintiffs, 1986 42 135 135. Pitts v. Freeman - Plaintiffs' Second Set of Interrogatories, 1986 42 136 136. Pitts v. Freeman - Plaintiffs' Third Set of Interrogatories, 1986 42 137 137. Pitts v. Freeman - Stipulation of the Parties for an Order Extending the Time Period of Discovery, 1986 42 138 138. Pitts v. Freeman - Defendants Answers and Responses to Plaintiffs Second Set of Interrogatories, 1986 42 139 139. Pitts v. Freeman - Plaintiffs' Responses to Defendants' First Interrogatories, 1986 42 140 140. Pitts v. Freeman - Plaintiffs' Responses to Defendants' Second Interrogatories, 1986 box folder Request box 43 1 141. Pitts v. Freeman - Plaintiffs' Motion to Submit Additional Interrogatories to Defendants, 1986 43 2 142. Pitts v. Freeman - Defendants' Responses to Plaintiffs' Third Set of Interrogatories, 1986 43 3 143. Pitts v. Freeman - Motion to Compel Defendants to Answer Plaintiffs' Third Set of Interrogatories, 1986 43 4 144. Pitts v. Freeman - Notice of Taking Deposition Upon Oral Examination, 1986 43 5 145. Pitts v. Freeman - Notice of Deposition, 1986 43 6 146. Pitts v. Freeman - Defendants' Supplemental Response to Plaintiffs' First Set of Interrogatories, 1986 43 7 147. Pitts v. Freeman - Defendants' Response to Motion to Compel Defendants to Answer Plaintiffs' Third Set of Interrogatories, 1986 43 8 148. Pitts v. Freeman - Objections of Bill Strain to Inspection and Copying of Designated Materials, 1986 43 9 149. Pitts v. Freeman - Notice of Deposition, 1986 43 10 149a. Pitts v. Freeman - Synopsis of Anticipated Testimony of Dr. David J. Armor, 1986 43 11 149b. Pitts v. Freeman - Synopsis of Anticipated Testimony of Dr. Herbert J. Walberg, 1986 43 12 150. Pitts v. Freeman - Defendants' Answers and Responses to Plaintiffs' Third Set of Interrogatories, 1986 43 13 150a. Pitts v. Freeman- Steven Parker Cole Curriculum Vitae, 1986 43 14 150b. Pitts v. Freeman - Rule 26 Statement on Plaintiffs' Proposed Expert- Robert Dentler, 1986 43 15 151. Pitts v. Freeman - Notice of Taking Deposition Upon Oral Examination, 1986 43 16 152. Pitts v. Freeman - Plaintiffs' Request for Production of Documents and Fourth Set of Interrogatories, 1986 43 17 153. Pitts v. Freeman - Notice of Appearance, 1986 43 18 154. Pitts v. Freeman - Plaintiffs' Request for an Extension of Time Within Which to Complete Discovery and for a Resetting of the Date for Hearing on Motion for Dismissal, 1986 43 19 155. Pitts v. Freeman - Motion and Brief Requesting Permission to Withdraw as Attorney of Record, 1986 43 20 156. Pitts v. Freeman - Defendants' Memorandum in Opposition to Plaintiffs' Motions of November 17, 1986, 1986 43 21 157. Pitts v. Freeman - Plaintiffs' Motion to Require Defendants to Produce the Data Requested in Plaintiffs' Fourth Interrogatories in a Merged Form, and for Reconsideration of Motion to Extend Discovery and Reschedule Hearing Date, 1986 43 22 158. Pitts v. Freeman - Defendants' Reply to Plaintiffs' Motion to Require Defendants to Produce Data in Merged Form and for Reconsideration of Motion to Extend Discovery and Reschedule Hearing Date, 1986 43 23 159. Pitts v. Freeman - Plaintiffs' Reply Brief in Support of Motions for Merger and Reconsideration, 1986 43 24 160. Pitts v. Freeman - Notice of Taking Deposition Upon Oral Examination, 1987 43 25 161. Pitts File - Discovery- Production of Documents, 1987 43 26 162. Pitts v. Freeman - Stipulation Regarding Discovery, 1987 43 27 163. Pitts File - Memorandum, 1987 43 28 164. Pitts v. Freeman - Defendants' Proposed Pre-trial Order, undated 43 29 165. Pitts v. Freeman - Stipulation of Deposition of Dr. Herbert J. Walberg, 1987 43 30 166. Pitts v. Freeman - Civil Action No. 11946, 1987 43 31 167. Pitts v. Freeman - Civil Action No. 11946, 1987 43 32 168. Pitts v. Freeman - Motion of Amicus Curiae League of Women Voters of DeKalb County for Leave to File Brief, undated 43 33 169. Pitts v. Freeman - Brief of Amicus Curiae League of Women Voters of DeKalb County, 1987 43 34 170. Pitts v. Freeman - Plaintiffs' Trial Brief in Opposition to Defendants' Motion to Dismiss, 1987 43 35 171. Pitts v. Freeman - Plaintiffs' Proposed Findings of Fact and Conclusions of Law Findings of Fact, 1987 43 36 172. Pitts v. Freeman - Defendants' Proposed Findings of Fact Student Assignment, 1987 43 37 173. Pitts v. Freeman - Defendants' Proposed Conclusions of Law on Motion to Dismiss, 1987 43 38 174. Pitts v. Freeman - Subpoenas, 1987 43 39 175. Pitts v. Freeman - Transcript of Proceedings, 1987 43 40 176. Pitts v. Freeman - Plaintiffs' Motion for Supplemental Relief, 1987 43 41 177. Pitts v. Freeman - Defendants' Brief in Response to Plaintiffs' Motion for Supplemental Relief, 1987 43 42 178. Pitts v. Freeman - Defendants' Amended Proposed Findings of Fact, 1987 43 43 179. Pitts v. Freeman - Defendants' Post Trial Brief in Support of Their Motion for a Declaration of Unitary Status and for Final Dismissal, 1987 43 44 180. Pitts v. Freeman - Plaintiffs' Motion to Require Defendants to File Junior High Plan, 1987 43 45 181. Pitts v. Freeman - Plaintiffs' Post- Trial Brief in Opposition to Defendants' Motion for Declaration of Unitary Status and Final Dismissal, 1987 43 46 182. Pitts v. Freeman - Defendants' Reply to Plaintiffs' Post Trial Brief in Opposition to Motion for a Declaration of Unitary Status and for Final Dismissal, 1987 43 47 183. Pitts v. Freeman - Defendants' Brief in Response to Plaintiffs' Motion to Require Defendants to File Junior High Plan, 1987 43 48 184. Pitts v. Freeman - Plaintiffs' Motion for Reconsideration, 1988 43 49 185. Pitts v. Freeman - Defendants' Response to Plaintiffs' Motion for Reconsideration, 1988 43 50 186a. Pitts v. Freeman - Record Excerpts Volume I, 1988 43 51 186b. Pitts v. Freeman - Record Excerpts Volume II, 1988 43 52 187a. Pitts v. Freeman - Transcript of Proceedings, 1988 43 53 187b. Pitts v. Freeman - Plaintiffs' Motion for Award of Costs and Attorney's Fees, 1988 43 54 188. Pitts v. Freeman - Notice of Appeal, 1988 43 55 189. Pitts v. Freeman - Petition for Leave to Appeal, 1988 43 56 190. Pitts v. Freeman - Petition for Leave to Appeal, 1988 43 57 191. Pitts v. Freeman - Notice of Appeal, 1988 43 58 192. Pitts v. Freeman - Plaintiffs' Response to Defendants' Petition for Leave, 1988 43 59 193. Pitts v. Freeman - Answer of Respondents to Petition for Leave to Appeal, 1988 43 60 194. Pitts v. Freeman - Appearance of Counsel Form, 1988 43 61 195. Pitts v. Freeman - Joint Motion to Designate Previous Orders as Part of the Record on Appeal, 1988 43 62 196. Pitts v. Freeman - Joint Motion to Consolidate Appeals, 1988 43 63 197. Pitts v. Freeman - Appearance of Counsel Form, 1988 43 64 198. Pitts v. Freeman - 88-8687 and 88-8775, 1989 43 65 199. Pitts v. Freeman - Joint Motion to Supplement the Record, 1989 43 66 200. Pitts v. Freeman - Appellants' Motion to Adjust Briefing Schedule, 1989 43 67 201. Pitts v. Freeman - Appellants' Motion for Extension of Time, 1989 43 68 202. Pitts v. Freeman - Brief for Plaintiff/ Appellants, 1989 43 69 203. Pitts v. Freeman - Brief of Defendants-Appellees, Cross- Appellants, 1989 43 70 204. Pitts v. Freeman - Stipulation for Dismissal with Prejudice of Plaintiffs' Motion for Award of Costs and Attorney's Fees, 1989 43 71 205. Pitts v. Freeman - Response of Appellant/ Cross- Appellee, undated 43 72 206. Pitts v. Freeman - Reply Brief of Appellees- Cross Appellants, undated 43 73 207. Pitts v. Freeman - Plaintiffs' Motion to Enforce Court's Orders, 1989 43 74 208. Pitts v. Freeman - Plaintiffs' Motion for a Temporary Restraining Order, 1989 43 75 209. Pitts v. Freeman - Complaint in Intervention, undated 43 76 210. Pitts v. Freeman - Plaintiffs' Interrogatories and Request for Production of Documents to Defendants, 1989 43 77 211. Pitts v. Freeman - Motion to Intervene in Limited Remedial Phases of this Action, 1989 box folder Request box 44 1 212. Pitts v. Freeman - Transcript of Proceedings, 1989 44 2 213. Pitts v. Freeman - Intervenors Complaint- Class Action, 1989 44 3 214. Pitts v. Freeman - Defendants' Response to Plaintiffs' Interrogatories and Request for Production of Documents to Defendants, 1989 44 4 215. Pitts v. Freeman v. Hooker - Motion to Intervene, 1989 44 5 216. Pitts v. Freeman v. Hooker - Intervenors' Motion for Partial Stay, 1989 44 6 217. Pitts and Paula White v. Freeman, 1989 44 7 218a. Plan of Implementation for Balanced Staffing, 1989 44 8 218b. Pitts v. Freeman - Plaintiffs Objections to Defendants' Plan, 1989 44 9 219. Pitts v. Freeman v. Ramona Hooker - Intervenors' Motion for Reconsideration and Request for Expedited Hearing, 1989 44 10 220. Pitts v. Freeman v. Ramona Hooker - Record Excerpts, 1989 44 11 221. Pitts v. Freeman - Defendants' Response to Plaintiffs' Motion to Enforce Court's Orders, 1989 44 12 222. Pitts v. Freeman - Appellants' Motion to Supplement the Record with Additional Developments, 1989 44 13 223. Pitts v. Freeman - Notice of Appeal and Request for Expedited Appeal, 1989 44 14 224. Pitts v. White v. Freeman - Plaintiffs- Intervenors Emergency Motion for Consolidated Oral Argument, 1989 44 15 225. Pitts and Paula White v. Freeman - Notice of Appeal, 1989 44 16 226. Pitts v. Freeman v. Ramona Hooker - Designation of the Record, 1989 44 17 227. Pitts v. Freeman v. Ramona Hooker - Emergency Motion for Expedited Appeal, 1989 44 18 228. Pitts and Paula White v. Freeman - Emergency Motion for Expedited Processing of Appeal, 1989 44 19 229. Pitts and White v. Freeman - Emergency Motion for Consolidated Oral Argument, 1989 44 20 230. Pitts v. Freeman - Proposed Intervenors White's and Wolford's Motion for Expedited Processing of Record for Purposes of Appeal in Main Action, 1989 44 21 231. Pitts v. Freeman - Appeal Information Sheet, 1989 44 22 232. Pitts v. Freeman - Brief of Plaintiff- Intervenors- Appellants White and Wolford, 1989 44 23 233a. Pitts v. Robert Freeman v. Ramona Hooker - Brief of Appellants Ramone Hooker, 1989 44 24 233b. Pitts v. Freeman - Petition for Leave of Absence, 1989 44 25 234a. Pitts v. Freeman - Defendants' Response to Plaintiff's Interrogatories and Request for Production of Documents to Defendants, undated 44 26 234b. Pitts v. Freeman - Appeal Information Sheet, 1989 44 27 235. Pitts v. White, Wolford v. Ramona Hooker v. Freeman - Brief of Defendants- Appellees Robert Freeman, 1989 44 28 236. [Empty], undated 44 29 237. Pitts v. Freeman v. White, Wolford v. Hooker - Brief for Plaintiffs- Appellees Pitts, 1989 44 30 238. Pitts v. Freeman v. Hooker - Reply Brief of Appellants' Ramona Hooker, et al. to Briefs of Appellees' Pitts, et al and Freeman, et al, 1989 44 31 239. Pitts v. White v. Hooker v. Freeman - Reply Brief for Appellants- Intervenors White and Wolford, 1989 44 32 240. Pitts v. Freeman v. Hooker - Amended Certificate of Service, 1989 44 33 241. Pitts v. Freeman - 89-8612, 1989 44 34 242. Certificate of Service, 1989 44 35 243. Pitts v. Freeman - Report to the Court, 1989 44 36 244a. Hearing Location, 1989 44 37 244b. Pitts v. Freeman - Motion and Brief Requesting Permission to Withdraw as Attorney of Record, 1989 44 38 245a. Pitts v. Freeman - Bill of Costs, 1989 44 39 245b. Pitts v. Freeman - Motion for Attorney Fees and Costs, 1989 44 40 246. Pitts v. Freeman - Suggestion of Rehearing in Banc, 1989 44 41 247a. Pitts v. Freeman - Brief in Response to Motion for Attorney Fees and Costs, 1989 44 42 247b. Pitts v. Freeman - Bill of Costs, 1989 44 43 248. Pitts v. Freeman - Motion to Stay the Mandate, 1989 44 44 249. Pitts v. Freeman - Bill of Costs Case No. 89-8612, 1989 44 45 250. Pitts v. Freeman - Appellants' Response to Motion to Stay, 1989 44 46 251. Pitts v. Freeman - Application for a Stay Pending Certiorari, undated 44 47 252. Freeman v. Pitts - Petitioners' Response to Application for Stay, 1989 44 48 253. Freeman v. Pitts - Reply to Opposition to Petitioners' Application for a Stay Pending Certiorari, 1989 44 49 254. Pitts v. Freeman - Amendment to Motion for Attorney Fees and Costs, 1989 44 50 255. Pitts v. Freeman - Motion for Attorney Fees and Costs, 1989 44 51 256. Pitts v. Freeman - Brief in Response to Motion for Attorney Fees and Costs, 1990 44 52 257. Pitts v. Freeman - Defendants' Response to Plaintiffs' Interrogatories and Request to Produce, 1990 44 53 258. Pitts v. Freeman - Complaint in Intervention, 1990 44 54 259. Pitts vs. Freeman - Motion to Intervene in Remedial Phases of this Action, 1990 44 55 260. Pitts v. Freeman - Appearance Form, 1990 44 56 261. Pitts v. Freeman - Petition for a Writ of Certiorari to the United States Court of Appeals, 1990 44 57 262. Pitts v. Freeman - Plaintiffs' Response to Complaint in Intervention, 1990 44 58 263. Pitts v. Freeman - Memorandum in Response to Plaintiff- Intervenors' Motion to Intervene in Remedial Phases of this Action, 1990 44 59 264. Pitts v. Freeman - Motion to Intervene or, in the Alternative, to Create a Subclass, 1990 44 60 265a. Pitts v. Freeman - Brief in Support of the Petition for Certiorari on Behalf of Georgia School Boards Association, 1990 44 61 265b. Pitts v. Freeman - Brief Amicus Curiae of the National School Boards Association in Support of the Petition for Writ of Certiorari, 1989 44 62 266. Pitts v. Freeman - Motion for Extension of Time to Submit Report, 1990 44 63 267. Pitts v. Freeman - Plaintiffs' Opposition to Defendants Motion for Extension of Time, 1990 44 64 268a. Pitts v. Freeman - Plaintiffs' Interrogatories, 1990 44 65 268b. Pitts v. Freeman - Respondents' Brief in Opposition, 1989 44 66 269. Pitts v. Freeman - Plaintiff- Intervenor Taylor et. al.'s Reply to Brief to Plaintiffs' and Defendants' Opposition to Their Intervention Motion, 1990 44 67 270. Pitts v. Freeman - Plaintiffs' Motion for Extension of Time in Which to Respond to Proposed Intervenors Armstrong et. al., 1990 44 68 271a. Pitts v. Freeman, circa 1990 44 69 271b. Pitts v. Freeman - Reply Brief of Petitioners, 1990 44 70 272. Pitts v. Freeman - Memorandum in Response to Plaintiff- Intervenors' Motion to Intervene, 1990 44 71 273. Pitts v. Freeman - Report to the Court on Status of Compliance with Court of Appeals Mandate, Junior High Plans, and Bond Fund Expenditures, 1990 44 72 274a. Pitts v. Freeman - Plaintiffs' Answer to Complaint in Intervention (Armstrong et. al.), 1990 44 73 274b. Pitts v. Freeman - Plaintiffs' Memorandum of Law in Response to Armstrong et. al. Complaint in Intervention, 1990 44 74 275. Pitts v. Freeman - Plaintiffs' Objections to Defendants' Report, 1990 44 75 276. Pitts v. Freeman - Reply Brief of Plaintiff- Intervenors Ashley and B'randi Armstrong in Support of their Motion to Intervene or, in the Alternative, to Create a Subclass, 1990 44 76 277. Pitts v. Freeman - Petition for Leave of Absence, 1990 box folder Request box 45 1 278a. Pitts v. Freeman - Defendants' Answers to Plaintiffs' Interrogatories, 1990 45 2 278b. Pitts v. Freeman - Transcript of Proceedings, 1990 45 3 279. Pitts v. Freeman - Defendants' Motion that a Hearing Be Held to Determine Adequacy of Current Class Representation, 1990 45 4 280. Prather v. Freeman - Plaintiffs' Motion to Join or Add Parties, 1990 45 5 281. The Board of Education of Oklahoma City v. Dowell, 1989 45 6 282. Prather v. Freeman - Defendants' Motion to Reschedule Hearing Date, to Extend Discovery and to Reset Briefing Schedule, 1990 45 7 283. Prather v. Freeman - Armstrong Intervenors' Motion for Extension of Time and Brief in Support Thereof, 1990 45 8 284. Prather v. Freeman - Notice to Take Deposition, 1990 45 9 285. Prather v. Freeman - Request for Production, 1990 45 10 286. Prather v. Freeman - Plaintiff Intervenors' Request for Pre-trial Identification of Witnesses, 1990 45 11 287. Prather v. Freeman - Motion for Expedited Hearing, 1990 45 12 288. Prather v. Freeman - Plaintiffs' Motion to Compel Discovery, Enforce Courts' Order, Convene Discovery Conference, and Appoint a Monitor to Assure Flow of Information and Memorandum in Support Thereof, 1990 45 13 289. Pitts v. Freeman - Defendants' Supplemental Answers to Plaintiffs' Interrogatories, 1990 45 14 290. Prather v. Freeman - Entry of Appearance of Willia Abrams as Counsel for Plaintiffs, 1990 45 15 291a. Prather v. Freeman - Defendants' May Call List of Witnesses for Hearing Scheduled to Begin August 6, 1990, 1990 45 16 291b. Prather v. Freeman - Intervenors' May Call List of Witnesses for Hearing Scheduled to Begin August 6, 1990, 1990 45 17 292. Pitts v. Freeman - Motion for Leave to File a Brief, 1990 45 18 293. Prather v. Freeman - Plaintiffs' Response to Request for Production, 1990 45 19 294a. Prather v. Freeman - Plaintiffs' Motion for a Preliminary Injunction, to Enforce the Mandate of the Court of Appeals and to Enforce the Orders of this Court, 1990 45 20 294b. Prather v. Freeman - Application for Admission to Pro Hac Vice, 1990 45 21 295. Willie Eugene Pitts, et al. v. Robert R. Freeman, et al. United States District Court, Atlanta Division, 1990 45 22 296. Prather v. Freeman - Defendants' Memorandum with Respect to Matters to be Heard on August 6, 1990, 1990 45 23 297. Prather v. Freeman - Brief in Response to Plaintiffs' Motion to Compel Discovery, Enforce Courts' Orders, Convene Discovery Conference, and Appoint a Monitor to Assure Flow and Memorandum in Support Thereof, 1990 45 24 298. Plaintiffs' Pre- Hearing Memorandum of Law, 1990 45 25 299. Prather v. Freeman - Armstrong, et al., Intervenors' Brief Regarding Proper Class Representation, 1990 45 26 300. Prather v. Freeman - Armstrong Intervenor, et al. Brief in Opposition to Plaintiffs' Motion to Add or Join Parties, 1990 45 27 301. Prather v. Freeman - Defendants' Response to Plaintiffs' Motion for a Preliminary Injunction, to Enforce the Mandate of the Court of Appeals, and to Enforce the Orders of this Court, 1990 45 28 302. Prather v. Freeman - Defendants' Response to Plaintiffs' Motion for a Preliminary Injunction, to Enforce the Mandate of the Court of Appeals, and to Enforce the Orders of this Court, 1990 45 29 303. Prather v. Freeman - Notice of Deposition, 1990 45 30 303b. Prather v. Freeman - Plaintiff- Intervenors' Amended May Call List of Witnesses for Hearing Scheduled to Begin on August 6, 1990, 1990 45 31 304. Prather v. Freeman - Plaintiff Intervenors' Memorandum Regarding Defendants' Potential Obligation to Provide Attorney Fees to Intervening Parties, 1990 45 32 305. Prather v. Freeman - Defendants' Response to Plaintiffs' Motion for a Preliminary Injunction, to Enforce the Mandate of the Court of Appeals, and to Enforce the Orders of this Court, 1990 45 33 306. Defendants' Memorandum with Respect to Dissenting Class Member Participation, 1990 45 34 307a. Jefferson Cheek Deposition Designation, 1990 45 35 307b. Pitts v. Freeman - Supplemental Brief of Petitioners, 1990 45 36 308. Pitts v. Freeman - Plaintiffs' Motion for a Temporary Restraining Order and to Show Cause by Defendants Should Not be Held in Contempt, undated 45 37 309. Pitts v. Freeman - Response of Proposed Intervenors to Motion of Plaintiffs for Temporary Restraining Order, etc., 1990 45 38 310. Mills v. Freeman - Plaintiffs' Petition for Writ of Mandamus Addressed to the 11th Circuit, 1990 45 39 311. In re Pitts, Prather, etc., Petitioners - Supplement to Petition for Writ of Mandamus, 1990 45 40 312. Pitts v. Freeman - Amended Response of Proposed Intervenors to Motion of Plaintiffs for Temporary Restraining Order, etc., 1990 45 41 313. [Empty], undated 45 42 314. Mills v. Freeman - Motion for Attorney Fees and Costs, 1991 45 43 315. Mills v. Freeman - Notice of Appeal, 1991 45 44 316a. Mills v. Freeman - Brief in Response to Plaintiffs' January 1991 Motion for Attorney Fees and Costs, 1991 45 45 316b. Mills v. Freeman - Plaintiff- Intervenors' Notice of Cross Appeal, 1991 45 46 317a. Mills v. Freeman - Plaintiffs' Continuing Interrogatories to Defendants, 1991 45 47 317b. Re: 91-8065 Mills v. Freeman, 1991 45 48 318. Mills v. Freeman - Plaintiff's Motion for Extension of Time in Which to Submit Detailed Specification and Itemization for Request for Costs, Expenses and Attorney Fees, 1991 45 49 319. Mills v. Freeman - Appearance of Counsel Form, 1991 45 50 320. Mills v. Freeman - Plaintiffs- Appellants' Memorandum of Law on Jurisdictional Issues, 1991 45 51 321. Mills v. Freeman - Statement of Defendants- Appellees with Respect to Jurisdiction, 1991 45 52 322. Mills v. Freeman - Certification of Interested Persons, 1991 45 53 323a. Mills v. Freeman - Memorandum in Support of Plaintiffs' Motion for Award of Costs, Expenses and Attorney's Fees, 1991 45 54 323. Mills v. Freeman - Memorandum of Intervenor- Appellees, 1991 45 55 324. Mills v. Freeman - Statement of Defendants- Appellees with Respect to Jurisdiction and Timelines of Cross-Appeal, 1991 box folder Request box 46 1 325. Prather v. Freeman - Plaintiff Intervenors' First Request for Production of Documents to Defendants, 1991 46 2 326. Prather v. Freeman - Plaintiff Intervenors' First Set of Interrogatories to Defendants, 1991 46 3 327a. Mills v. Freeman - Memorandum of Intervenor- Appellees Regarding Jurisdiction and Timeliness of Cross- Appeal, 1991 46 4 327b. Mills v. Freeman - Defendants' Responses to the Mills Plaintiffs' Continuing Interrogatories to Defendants Dated February 6, 1991, 1991 46 5 328. Mills v. Freeman - Brief in Response to Plaintiffs' Memorandum in Support of Motion for Award of Costs, 1991 46 6 329. Plaintiff Intervenors' Second Set of Interrogatories to Defendants, 1991 46 7 330. Prather v. Freeman - Plaintiff Intervenors' First Request for Production of Documents to Defendants, 1991 46 8 331. Mills v. Freeman - Defendants' Responses to Armstrong Plaintiffs' First Request For Production of Documents to Defendants, 1991 46 9 332. Mills v. Freeman - Defendants Responses to Armstrong Plaintiffs' First Set of Interrogatories to Defendants, 1991 46 10 333. Mills v. Freeman - Plaintiffs' Reply Brief, 1991 46 11 334. Mills v. Freeman - Motion for Leave to File Supplemental Brief Addressed to Attorney Fee Issue, 1991 46 12 335a. Freeman v. Pitts - Brief of Southeastern Legal Foundation, Inc. as Amicus Curiae in Support of Petitioners, 1991 46 13 335b. Freeman v. Pitts - On Writ of Certiorari to the United States Court of Appeals for the Eleventh Circuit, 1990 46 14 336. Freeman v. Pitts - Brief Amicus Curiae of Plaintiff- Intervenors Seeking Reversal in Part and Affirmance in Part, 1991 46 15 337. Freeman v. Pitts - Brief of Petitioners, 1991 46 16 338. Freeman v. Pitts - Brief for the United States as Amicus Curiae Supporting Petitioners, 1990 46 17 339. Freeman v. Pitts - Motion for Divided Argument, 1991 46 18 340. Prather v. Freeman - Plaintiff Intervenors' Third Set of Interrogatories to Defendants, 1991 46 19 341. Prather v. Freeman - Plaintiff Intervenors' Third Request for Production of Documents to Defendants, 1991 46 20 342. Pitts v. Freeman - Petition for Leave of Absence, 1991 46 21 343. Prather v. Freeman - Motion for Leave of Absence, 1991 46 22 344a. Mills v. Freeman - Defendants' Responses to Armstrong Plaintiffs' Request for Production of Documents to Defendants Dated March 22, 1991, 1991 46 23 344b. Mills v. Freeman - Defendants' Responses to Armstrong Plaintiffs' Second Set of Interrogatories to Defendants, 1991 46 24 345. Freeman v. Pitts - Respondents Brief, 1990 46 25 346. Freeman v. Pitts - Brief for the Lawyers' Committee for Civil Rights Under Law as Amicus Curiae in Support of Respondents, 1991 46 26 347. Freeman v. Pitts - Brief of the NAACP, DeKalb County, Georgia, Branch of the NAACP, American Jewish Committee, Children's Defense Fund, Fund for an Open Society, Mexican American Legal Defense and Educational Fund, Puerto Rican Legal Defense and Educ, undated 46 27 348. Mills v. Freeman - Defendants' Responses to Armstrong Plaintiffs' Third Set of Interrogatories to Defendants, 1991 46 28 349. Freeman v. Pitts - Reply in Brief of Petitioners, 1991 46 29 350. Mills v. Freeman - Memorandum of Law in Support of Plaintiffs' Motion to Join or Add Parties, 1991 46 30 351. Mills v. Freeman - Plaintiff- Intervenors' Response to Plaintiffs' Motion to Join or Add Parties, 1991 46 31 352. Mills v. Freeman - Defendants' Memorandum in Response to the Mills Plaintiffs July, 1991 Motion to Join or Add Parties, 1991 46 32 353. Mills v. Freeman - Plaintiffs' Reply, 1991 46 33 354. Mills v. Freeman - Plaintiffs' Continuing Interrogatories to Defendants, 1991 46 34 355. Mills v. Freeman - Plaintiffs' Intervenors' Supplemental Response to Plaintiffs' Reply, 1991 46 35 356. Mills v. Freeman - Plaintiffs' Motion to Strike and Memorandum of Law in Support Thereof, 1991 46 36 357. Mills v. Freeman - Plaintiffs' Motion to Compel Discovery, Enforce Court's Orders, Convene Discovery Conference, to Show Cause Why Should Not Be Held in Contempt, and Appoint a Monitor to Assure Flow of Information and Memorandum in Support Thereof, 1991 46 37 358. Mills v. Freeman - Motion for Leave to File Supplemental Response and Conditional Motion to Strike, 1991 46 38 359. Mills v. Freeman - Defendants' Responses to Mills Plaintiffs' Interrogatories to Defendants Dated September 5, 1991, 1991 46 39 360. Supreme Court of the United States Freeman v. Pitts Certiorari to the United States Court of Appeals for the Eleventh Court, 1991 46 40 361. Pitts v. Freeman - On Remand from the Supreme Court of the United States of America, 1992 46 41 362. Pitts v. Freeman - Response of Appellees- Cross Appellants to Motion of Appellants on Remand from the Supreme Court, 1992 46 42 363. Pitts v. Freeman - Response of Plaintiff Intervenors to Motion of Appellants/ Cross- Appellees, 1992 46 43 364. Pitts v. Freeman - Notice of Appearance, 1992 46 44 365. Pitts v. Freeman - Response of Defendants Appellees- Cross Appellants to Response of Plaintiffs- Intervenors, 1992 46 45 366. Mills v. Freeman - Notice of Change of Address, 1992 46 46 367. Pitts v. Freeman - Statement of Position of Defendants- Appellees- Cross- Appellants on Action Required of the Court Prior to Remand to the District Court, 1992 46 47 368. Pitts v. Freeman - Brief of Appellants/ Cross Appellees, 1992 46 48 369. Pitts v. Freeman - Brief of Plaintiff- Intervenors Regarding Action to be Taken Prior to Remand, 1992 46 49 370. Mills v. Freeman - Petition for Leave of Absence, 1992 46 50 371. Mills v. Freeman - Brief in Support of Motion for Leave to Use Bond Proceeds, 1992 46 51 372. Mills v. Freeman - Response of Plaintiff- Intervenors to Defendants' Motion for Leave to Use Bond Proceeds, 1992 46 52 373. Mills v. Freeman - Plaintiffs Motion to Strike Defendants' Motion for Leave to Use Bond Proceeds, 1992 46 53 374. Mills v. Freeman - Plaintiffs' Motion for a Preliminary Injunction, to Show Cause Why Defendants Should Not be Held in Contempt, and to Enforce the Orders of This Court, 1992 46 54 375. Mills v. Freeman - Plaintiff's Supplemental Brief to the Court, 1992 46 55 376. Mills v. Freeman - Supplemental Response of Plaintiff- Intervenors to Defendant's Motion for Leave to Use Bond Proceeds, 1992 46 56 377. Mills v. Freeman - Brief in Response to Mills Plaintiffs' Motion to Strike and in Reply to Response of Armstrong Plaintiffs, 1992 46 57 378a. Pitts v. Freeman - Motion to Correct or Amend Judgment, 1992 46 58 378B. Pitts v. Freeman - Response of Appellees to Motion to Correct or Amend Judgment, 1992 46 59 379. Pitts v. Freeman - Brief of Plaintiff- Intervenors in Response to Motion of Appellant to Correct or Amend Judgment, 1992 46 60 380. Mills v. Freeman - Supplemental Brief on Bond Issue Question in Light of Court of Appeals Remand Order, 1992 46 61 381. Pitts v. Freeman - Plaintiffs' Reply, 1992 46 62 382. Mills v. Freeman - Response of Plaintiff- Intervenors to Supplemental Brief of Defendants on Bond Issue Question, 1993 46 63 383. Mills v. Freeman - Plaintiffs'- Intervenors Third Interrogatories to Defendants, 1993 46 64 384. Mills v. Freeman - Plaintiffs' Response to Defendants' Supplemental Brief on Bond Issue, 1993 46 65 385. Mills v. Freeman - Plaintiffs'/ Intervenors' March 1993 Request for Production of Documents, 1993 46 66 386. Mills v. Freeman - Plaintiffs' Interrogatory and Document Requests to Defendants, 1993 46 67 387. Mills v. Freeman - Defendants' Response to Armstrong Plaintiffs' Fourth Set of Interrogatories to Defendants, 1993 46 68 388. Mills v. Freeman - Certificate of Service, 1993 46 69 389. Mills v. Freeman - Defendants' Response to Armstrong Plaintiffs' March 1993 Request for Production of Documents, 1993 46 70 390. Mills v. Freeman - Defendants' Response to Armstrong Plaintiffs' March 1993 Request for Production of Documents, 1993 46 71 391. Mills v. Freeman - Motion to Withdraw as Counsel for Plaintiffs, 1993 46 72 392. Mills v. Freeman - Motion for Attorney Fees and Costs, 1993 46 73 393. Mills v. Freeman - Brief in Response to Motion of Marcia Borowski to Withdraw as Counsel for Plaintiffs, 1993 46 74 394. Mills v. Freeman - Brief in Response to Plaintiffs' May 13, 1993 Motion for Attorney Fees and Costs, 1993 46 75 395. Mills v. Freeman - Interrogatories to Defendants, 1993 46 76 396. Mills v. Freeman - Notice of Appeal, 1993 46 77 397. Mills v. Freeman - Notice of Appeal, 1993 46 78 398. Mills v. Freeman - Memorandum in Support of Motion for Equitable Relief from Overcrowding, 1993 46 79 399. Mills v. Freeman - Plaintiffs' Reply to Defendants' Response to Motion of Marcia Borowski to Withdraw as Counsel, 1993 46 80 400. Mills v. Freeman - Plaintiffs' Reply to Defendants' Brief on Attorney Fees and Costs, 1993 46 81 401. Mills v. Freeman - Report to the Court on Planned Expenditure of Proceeds from Unissued Bonds, 1993 46 82 402. Mills v. Freeman - Amended Notice of Appeal, 1993 46 83 403. Mills v. Freeman - Defendants' Response to Mills Plaintiffs' Interrogatories and Request to Produce, Dated July 7, 1993, 1993 46 84 404. Mills v. Freeman - Plaintiffs' Supplemental Brief on Attorney Fees and Costs, 1993 46 85 405. Mills v. Freeman - Brief in Response to Armstrong Plaintiffs' July 14, 1993 Motion for Equitable Relief from Overcrowding, 1993 46 86 406. Mills v. Freeman - Notice of Appeal, 1994 46 87 407. Mills v. Freeman - Notice of Cross- Appeal, 1994 46 88 408. Mills v. Freeman - Motion for Award of Attorney's Fees and Brief in Support Thereof, 1994 46 89 409. Mills v. Freeman - Amended Motion for Award of Attorney's Fees and Brief in Support Thereof, 1994 46 90 410. Mills v. Freeman - Stipulation for Dismissal with Prejudice of Plaintiffs- Intervenors Motion, As Amended, for Award of Attorney's Fees, 1994 46 91 411. Armstrong v. Freeman - Consent Motion to Dismiss Appeal, 1994 46 92 412. Mills v. Freeman - Brief in Support of Final Dismissal Upon Remand from Supreme Court and Court of Appeals, 1994 46 93 413. [Empty], undated 46 94 414. Mills v. Freeman - Notice of Substitution of Counsel, 1994 box folder Request box 47 1 415. Mills v. Freeman - Brief in Opposition to Motion For Final Dismissal Upon Remand, 1994 47 2 416. Mills v. Freeman - Brief of Plaintiff- Intervenors in Opposition to Defendants Request for Final Dismissal, 1994 47 3 417a. Mills v. Freeman - Plaintiff- Intervenors' March 1995 Interrogatories and Request for Production of Documents, 1995 47 4 417b. Mills v. Freeman - Supplemental Brief of Plaintiff- Intervenors In Opposition to Defendants' Request for Final Dismissal, undated 47 5 418. Mills v. Freeman - Notice that NAACP Staff Attorney Bruce K. Roberts is no Longer a Counsel for the Mills Plaintiffs in the Above- Styled Action, 1995 47 6 419. Mills v. Freeman - Defendants' Supplementary Responses to Armstrong Plaintiffs' Fourth Set of Interrogatories to Defendants, 1995 47 7 420. Mills v. Freeman - Defendants' Responses to Armstrong Plaintiffs' March 1995 Interrogatories and Requests for Production of Documents, 1995 47 8 421. Mills v. Freeman - Defendants' Supplementary Responses to Armstrong Plaintiffs' Second Set of Interrogatories to Defendants, 1995 47 9 422. Mills v. Freeman - Stipulation of Designation of Record, 1995 47 10 424. Mills v. Freeman - Defendants' Motion for Oral Argument, 1995 47 11 425. Mills v. Freeman - Appellants' Motion for Enlargement of Time for Filing Opening Brief and Record Excerpts, 1995 47 12 426. Mills v. Freeman - Appellants' Motion for Enlargement of Time for Filing Opening Brief and Record Excerpts, 1995 47 13 427. Mills v. Freeman - Plaintiffs' Motion for Enlargement of Time for Filing Brief Addressing Defendants' Motion for Final Dismissal, 1995 47 14 428. Mills v. Freeman - Motion of American Civil Liberties Union of Georgia to File Amicus Brief, 1995 47 15 429. Mills v. Freeman - Brief of Appellants, Cross- Appellees, Mills et al., 1996 47 16 430. Mills v. Freeman - Appellants' Motion for Voluntary Dismissal of Appeal, 1995 47 17 431. Mills v. Freeman - Brief of Plaintiff- Intervenors Pursuant to Order of September 8, 1995, 1995 47 18 432. Mills v. Freeman - Certificate of Interested Persons and Corporate Disclosure Statement for Appellants' Motion for Voluntary Dismissal, 1995 47 19 433. Mills v. Freeman - Mills Plaintiffs' Second Brief in Opposition to Defendants Motion for Final Dismissal Upon Remand, 1995 47 20 434. Mills v. Freeman - Motion of Counsel for the Mills Plaintiffs for Leave to File Brief Out of Time, 1995 47 21 435. Mills v. Freeman - Defendants'- Appellees Motion to Determine Jurisdiction and for an Extension of Time to File a Brief on the Merits, 1995 47 22 436. Mills v. Freeman - Response of Appellants, Cross- Appellees, Mills, et al. to Motion to Determine Jurisdiction, 1996 47 23 437. Mills v. Freeman - Defendants' Reply Brief in Support of Final Dismissal and in Response to Order of September 8, 1995, 1996 47 24 438. Mills v. Freeman - Affidavit of Charles S. Johnson, III, 1996 47 25 439. Mills v. Freeman - Affidavits of Plaintiff- Intervenors in Opposition to Defendants' Motion to Dismiss, 1996 47 26 440. Mills v. Freeman - Defendants' Notice of Evidentiary Filing, 1996 47 27 441. Mills v. Freeman - Proposed Findings of Fact and Conclusions of Law in Support of Final Dismissal, 1996 47 28 442. Mills v. Freeman - Motion for Leave to File Evidentiary Material and Brief in Support Thereof, 1996 47 29 443. Mills v. Freeman - Post Hearing Memorandum of Plaintiff- Intervenors, 1996 47 30 444. Mills v. Freeman - Motion for Oral Argument and Brief in Support Thereof, 1996 47 31 445. Mills v. Freeman - Response of Plaintiff- Intervenors to Defendants' Proposed Findings and Fact and Conclusions of Law, 1996 47 32 446. Mills v. Freeman - Hearing Memorandum, 1996 47 33 447. Joint Motion to Extend the Time for Filing Notice of Appeal and Brief in Support Thereof, 1996 47 34 448. Mills v. Freeman - Brief of Appellees, Cross- Appellants, 1996 47 35 449. Mills v. Freeman - Response Brief of Appellants, Cross- Appellees, Mills et al., 1996 47 36 450. Mills v. Freeman - Reply Brief of Defendants- Appellees, Cross- Appellees, 1996 47 37 451. Pitts v. Freeman - Unitary Status Pleadings and Orders, 1989 47 38 [Record Excerpts], 1983-1989 [Reports to the Court] box folder Request box 47 39 Report to the Court on Planned Expenditure of Proceeds from Unissued Bonds, 1993 47 40 Report to the Court as to the Change of Attendance Zones, 1983 47 41 Report to the Court, 1989 Regarding court order on June 30, 1988 to address and equalize the per pupil expenditure of funds among the three groups of schools as classified by plaintiffs. 47 42 Report to the Court, 1989 Regarding court order on June 30, 1988 to report to the court compliance with the standards for in-school professional staff distribution of Singleton v. Jackson Municipal Separate School District and to equalize the number of teachers with advanced degrees and more experienced teachers among the types of schools. 47 43 Report to the Court on Status of Compliance with Court of Appeals Mandate, Junior High Plans, and Bond Fund Expenditures, 1990 March 30 47 44 Plaintiff's Objections to Defendant's Report, 1990 Objections to defendants' "Report to the Court on Status of Compliance with Court of Appeals Mandate, Junior High Plans, and Bond Funding Expenditures" filed on March 30, 1990. 47 45 Plaintiffs' Objections to Defendants' Plan, 1989 Objections to defendants' "Plan of Implementation for Balanced Staffing" filed on July 14, 1989. 47 46 Plan of Implementation for Balanced Staffing, 1989 47 47 Report to the Court on Status of Compliance with Court of Appeals Mandate, Junior High Plans, and Bond Fund Expenditures, 1990 March 30 47 48 Plaintiffs' Objections to the Defendants' Report Objection to "Report to the Court on Status of Compliance with Court of Appeals Mandate, Junior High Plans, and Bond Funding Expenditures" filed on March 30, 1990. 47 49 [Supreme Court], 1990-1992 box folder Request box 48 1 [Supreme Court], 1978-1991 48 2-10 [Transcripts of Court Proceedings: Unitary Status], 1987 box folder Request box 49 1-4 [Transcripts of Court Proceedings: Unitary Status], 1987 49 5-12 [Transcripts of Court Proceedings], 1968-1990 box folder Request box R.50 1 [Transcripts of Court Proceedings], 1990
Series III. Working Files, 1946-1996 (1984-1996)
15 box(es)
(11.5 linear feet)
Series III. Working Files documents the research and thought processes of the lawyers in the case. The series includes data collected on the schools and research files, as well as correspondence, depositions, and notes. Common subjects include DeKalb County Schools financial records and calculations of per pupil expenditures, plans for addressing overcrowding at Redan High School, statistics about teachers and staff, enrollment numbers of students include race, school facility capacity, the magnet school program, and DeKalb County School policies. This series is open for research with the following exceptions. Boxes with restricted materials are identified with an R before the box number. An access restriction note follows each restricted folder title with an explanation of the restriction and when the folder will be open. 1. Attorney-client privileged materials are restricted for 50 years from the date of the folder. 2. Folders with large numbers of social security numbers or student records protected by FERPA are currently restricted. 3. Some boxes in this series must be reviewed for account numbers prior to research use. Please request these boxes 3 business days prior to your research visit to allow time for this review. The files were sorted into these categories by Russell staff. These files did not come to the library with any clear organization. Correspondence
The majority of the correspondence is between lawyers about the case progress, court orders, and drafting documents to submit to the court. The correspondence also includes draft documents, newspaper articles about the case, and correspondence with DeKalb County Schools officials about the case. box folder Request box R.50 2-8 [Correspondence], 1989-1995 Folder 6 and Folder 8 must be reviewed for restricted account numbers prior to research use. Please request this box 3 business days prior to your research visit to allow time for this review. box folder Request box 52 1-2 [Correspondence], 1995-1996 box folder Request box R.29 17 [Correspondence], 1991 This folder contains restricted attorney-client privileged records and is open for research on January 1, 2042. R.29 18 [Correspondence], 1991-1992 This folder contains restricted attorney-client privileged records and is open for research on January 1, 2043. R.29 19 [Correspondence], 1994 This folder contains restricted attorney-client privileged records and is open for research on January 1, 2045. box folder Request box R.63 1 [Correspondence], 1968-1975 This folder contains restricted attorney-client privileged records and is open for research on January 1, 2026. Data box folder Request box 52 3 [School Enrollment, Capacity, and Per Pupil Expenditure], 1991-1996 Data fields are Capacity Chart, Teaching Stations, M-to-M, Race, Space Available 52 4 [Per Pupil Expenditure], 1989-1992 Data fields are School Number, School Name, Average ADA, Total Expenditure 52 5 [Documents for Preparation for Unitary Status Hearings], 1946-1987 52 6 [Per Pupil Expenditure], 1994-1995 Data fields are Per Pupil Expenditure, AVG ADA [Average Daily Attendance], School Name 52 7 Attendance Districts, 1991-1993 52 8 Mobile Units, 1979-1983 Data fields are Number Requested, Total on Site & Requested, Projected Enrollment, Comments 52 9 Capacity Chart, 1992-1993 Data fields are Predominantly White or Black School, Teaching Stations, Net Capacity, Projected Enrollment, New M-to-M, Black, Total Space Available, Comments 52 10 DeKalb County School System Personnel Report, 1993 Data fields are Category, Positions Filled Since June 1993, White, Black, New, Transferred, Total Number of Faculty, School Name, Transferred From 52 11 Mills v. Freeman C.A No. 11946, 1992-1995 Data fields are School, Type, School Name, Administration, Media Services, Pupil Services, Instructional, Total Staff 52 12 Expenditures per Pupil - DeKalb County Schools Fiscal Year [1985-1986], 1987 Data fields are School % Black, ADA [Average Daily Attendance], Per Pupil Expense, Chapter I Expense, Pct. Black Students, Pct. S.E. Students, AVG. Age of Staff, ADA [Average Daily Attendance]/Prof. Staff Ratio 52 13 [Programs: Open Campus, Remedial Education Program, Gordon/Walker Project, Language Arts Laboratory, Hamilton Alternative School, International Student Center, DeKalb School for the Performing Arts, Scientific Tools and Techniques, Foreign Language Magnet, undated Data fields are Program, Total Cost, Number of Students Served, Cost Per Student, Percentage of Black Students Served, Comment on Enhancement of Integration Via This Program 52 14 Atlanta Region Census Profiles [1990], 1992 Data fields are Tract, Total Population, Total Households, Percent of Population Black and Other Races, Percent of All Persons (For Whom Poverty Status is Determined) Below Poverty, Percent of all Households Below Poverty, Median HH Income, Percent of Population Over 65, Percent Unemployment, Percent of Unemployment Among 16-19 Year Olds, Percent Labor Force Participation, Percent of Owner-Occupied Units by Same Householder Since Before 1980, Percent of All Persons (Age 25 and Over) with a College Degree or Higher, Percent of all Housing Units with Complete Kitchen Facilities, Percent of all Housing Units with Complete Plumbing Facilities. 52 15 Summary of DeKalb County Survey Results, 1990 Questions address rating of school quality, opinion of different methods of integration, magnet programs, and busing. Divides responses by black parents and nonblack parents. 52 16 School Profile [1990-1991], 1990 Data fields are School, Percent Black, Percent White, Percent Other, Total Enrollment, Gross Capacity, Net Capacity 90-91, Staff, Years Present Position, Previous Position 52 17 [Enrollment], 1984-1991 52 18 [Bond Fund Matters], 1991 Includes documents, statistics, and maps about computer use, building renovations, and preliminary projections of the racial makeup of each school [1991-1992] 52 19 DeKalb County Schools Statement of Receipts and Disbursements - General Operation (K-12) Budget and Actual For Month [1990-1991], 1990-1991 Data fields are Appropriations, Activity/Variances, Receipts, Budget Annual, Budget Month, Actual for Month, Over/Under Budget, Actual Year-to-Date 52 20 [Number of Rooms and Mobile Units] [1989-1990], 1990 Data fields are Magnet Schools, Teaching Stations, Special Rooms Before Magnet Program, Special Rooms for Magnet Program, Net Reg Rooms, Enroll Non-Magnet Students, Seats, Mobile 89-90, Units 90-91, Mobile Unites Non-Magnet Students 52 21 Capacity Chart [1991-1992] Space Available, M-to-M, 1991 Data fields are Predominantly White School, Teaching Stations, Capacity at 26:1, Projected Enrollment, New M-to-M in 90-91, Black Enrollment 12-90, Projected Enrollment Minus New M-to-M, Total Space Available, Comments 52 22 Per Pupil Expenditure: Magnet Programs & Special Education [1991-1992], 1992 Data fields are School Number, School Name, ADA [Average Daily Attendance], Average ADA [Average Daily Attendance], Total Expenditures, Expenditures Per Pupil 52 23 DeKalb County Schools Recap of Per Pupil Expenditures Fiscal Year [1991-1992], 1992 Data fields are School Number, School Name, ADA [Average Daily Attendance], Average ADA [Average Daily Attendance], Total Expenditures, Expenditures Per Pupil 52 24 Federal Compliance Report, 1992 52 25 Personnel Report, undated Data fields are Schools, Number of Positions Filled Since June 10, 1969, Race, New, Transferred, Total Number of Facilities 52 26 Enrollment of Selected Magnet Programs [1987-1992], 1992 Data fields are Program, Black, White, Total 52 27 Enrollment Projections [1992-1993], 1992 Data fields are Grade, Attendance Area Students, Magnet Students, Total 52 28 Enrollment as of April 10, 1992, 1992 Data fields are School, Grades, %White, %Black, %Other, Principal's Race 52 29 [Room Needs], undated Data fields are Schools, Certified Teacher, D'cate Room, Special Education Teacher, Room Need, Projected Difference, Projected Adj, Reg Clrms, Mobile Units, Total Rooms, Difference, M/M Seat 52 30 [Verification that Received Calendar], 1992 52 31 Notice to all Counsel of Record, 1992 52 32 Capacity [1990-1995], 1992 Projected Capacity Data fields are School, Grade, %Capacity 52 33 Capacity [1989-1997], 1992 Data fields are School, Grade, %Capacity, Projected M-to-M box folder Request box 53 1 Per Pupil Expenditure [1991-1992], 1992 Data fields are School Number, School Name, Average ADA [Average Daily Attendance], Total Expenditures, Expenditures per Pupil 53 2 Recap of Per Pupil Expenditures [1991-1992], 1992 Data fields are School, ADA [Average Daily Attendance], Per Pupil Expenditure 53 3 Personnel Report, 1990 Data fields are Category, Positions Filled Since June 1990, Positions, White, Black, New, Transferred, Total Number of Faculty Members 53 4 Distribution of In-School Certificated Staff, 1990 Data fields are School, Certificated Staff, White, Black, Percent Black, Race of Principal, Majority Race of Population, Average Years Training, Average Years Experience 53 5 Recap of Per Pupil Expenditures [1988-1989], 1990 Data fields are School, ADA [Average Daily Attendance], Per Pupil Expenditure 53 6 Racial Composition DCSS [DeKalb County School System] Schools [1955-1986], undated Data fields are Year, School, Number Black, Number White, Number Other, %Black, Total Students 53 7 Recap of Per Pupil Expenditures [1989-1990], 1991 Data fields are School, Per Pupil Expenditure, ADA [Average Daily Attendance] 53 8 Capacity and Mobile Units [1991-1992], 1991-1992 53 9 Per Pupil Expenditure, undated box folder Request box R.64 1 Salary to be Added to Receiving Schools, Salary to be Subtracted from Former Schools, 1990 This folder contains a large number of social security numbers and is currently restricted. box folder Request box 53 10 General Ledger Master, 1978, 1981 53 11-12 Admin-Policy-Sch, 1990 Date fields are School Department Number, School Department Name 53 13 DeKalb County School System Student Absentee Analysis Report, 1st-4th 20 Day, 1990-1991 Data fields are School, A.D.M., Absences, Percent of A.D.A., A.D.M. Change, Absence Change, Percent A.D.A. Change, Special Education Absences 53 14 Elementary Professional Staffing Report June 1990, 1990 Data fields are School, Type, Student Enroll., Total Professional Sta, Assistant Principal, School Psychologist, Social Worker, Type 2,3 Staff Allotment, Chapter I Math, Writing Program,, Bidialectal Speech Program, Reading Spec., Reading Consultant, REP 53 15 DeKalb County Schools Recap of Per Pupil Expenditures Fiscal Year 1989-1990, 1989-1990 Data fields are School, ADA [Average Daily Attendance], Per Pupil Expenditure 53 16 DeKalb County School System Distribution of In-school Certified Staff April, 1991, 1991 Data fields are School, Certified Staff, White, Black, Percent Black 53 17 Special Use Room Summary (School Year 91-92), 1991-1992 Data fields are School Name, Number, Room Use 53 18 Number of Active M-to-M Students by Home School and Grade, 1992 Data fields are School, Grade, Total 53 19 Business & Plant Service: Rock Springs/Patillo School Site, 1992 November 11 53 20 Projects Funded from the General Fund Monies that were Originally Planned to Come from the 1989 Bond Authorization, undated Data fields are Project Number, Project Name, Cost 53 21 Magnet Classes Assigned to Mobile Units, undated Data fields are Magnet Site, Number of Magnet Classes Assigned to Mobile Units 53 22 Location of Mobile Units [1991-992], 1992 Data fields are Elementary Schools, High Schools, Centers, Grand Total 53 23 Sites Purchased Since 1965, 1992 53 24 Analysis of Professional Staff Balance, 1992 October 23 53 25 Enrollment [1991-1992], 1991 Data fields are Grade Level, White, Other, Black, Present School, Student Number 53 26 Magnet School Capacities, 1992 Data fields are School Name, Current Capacity, Rooms Reserved for Magnet Program, Capacity Including Magnet Rooms 53 27 Magnet Programs Enrollment, 1992 Data fields are Magnet Program, White/Other, Black, Total Students 53 28 Magnet Program Applications by Present School [1992-1993], 1992 Data fields are Grade Level, Black, White/Other, Present School 53 29 DeKalb County School System Distribution of In-School Certificated Staff, 1992 October 23 Data fields are School, Type, Certificated Staff, White, Black, Percent Black 53 30 DeKalb County School System Personnel Report, 1992 October 23 Data fields are Category, Positions Filled Since 1991, Positions White, Positions Black, Positions New, Positions Transferred, Total Number of Faculty Members, Total White, Total Black 53 31 Rough Outline of Analysis, undated 53 32 DeKalb County School System Existing Magnet and Educational Enrichment Programs, 1982-1991 Data fields are Program, Year, Totals, Expenditures 53 33 Certificate of Service, 1990 53 34 Personnel Report - DeKalb County School System Showing Faculty Positions Filled Because of the Creation of New Positions, Resignations, and/or Transfers, 1989 Data fields are Category, Number of Positions Filled Since June 1989, Positions Filled, White, Black, New, Transferred, Total Number of Faculty Members box folder Request box R.64 2 Update of 1989 Teacher Lottery, 1993 Data fields are Last Name, First name, SSN, AS, Term. Reason, TOD, School, Lottery Number, Race, Sex This folder contains a large number of social security numbers and is currently restricted. box folder Request box 53 35-36 DeKalb County School System Area School Profiles, 1990 Data fields are School, Type/Area, Professional Staff, Number White, Number Black, Percent Black Staff, Average/Years Experience Staff, Number of Administrators, Percent Black Administrators, Average Degree Staff, Total Enroll., Percent Black Student, Net 53 37 DeKalb County Schools General Operations (K-12) Expenditures Per Pupil Fiscal Year 1988-1989, 1993 Data fields are School Number, School Name, ADA [Average Daily Attendance], Average ADA [Average Daily Attendance], Total Expenditures, Expenditures Per Pupil 53 38 Current Student Discipline Report [1990-1991], 1991 Data fields are School, Black, White, Other, Number, Percent, Total box folder Request box 62 1 High School and Special Education Applicants Received in Calendar Year 1986, undated Data fields are Name, Position Applied, Race, Date of Application, Employment Status 62 2 Systemwide Professional Applicants Received in Calendar Year 1986, undated Data fields are Name, Position Applied, Race, Date of Application, Employment Status 62 3 Elementary School Applicants Received in Calendar Year 1986, undated Data fields are Name, Position Applied, Race, Date of Application, Employment Status box folder Request box R.64 1 Staff Report, 1987 Data fields are Principal, Teachers, Last Name, First Name, Certification, Grade, Race, SSN, TOD, Reason This folder contains a large number of social security numbers and is currently restricted. R.64 2 Staff Salary Report [High School], 1987 Data fields are SSN, Years of Service, Name, Certification, Race, Grade, Title, Annual Salary This folder contains a large number of social security numbers and is currently restricted. R.64 3 Staff Salary Report [Elementary School], 1987 Data fields are SSN, Years of Service, Name, Certification, Race, Grade, Title, Annual Salary This folder contains a large number of social security numbers and is currently restricted. box folder Request box 62 4 DeKalb School Administrators by Date of Initial Hire, 1986 Data fields are Employee Name, Date Employed, Race, Sex, Position Title box folder Request box R.65 4 DeKalb Data Set Reduced Lunch, circa 1986-1987 Data fields are Variable Name, Student ID, Grade, Race, Percent Free/Reduced Lunch, Total Battery CAT 84 This folder contains student records protected by FERPA and is currently restricted. box folder Request box 62 5 Applications Received Since 1984 that have been Employed, undated Data fields are Name, Application Received, Race, Position Applied For, Current Position DeKalb Schools box folder Request box 53 39 [1991-1992 Preliminary Budget], 1991 53 40 [Annual Financial Aid Report], 1993 53 41 [Assessments], 1984-1990 53 42 [Bonds], 1989-1990 53 43 [Chamblee/Dunwoody Merger], 1991 53 44 Pitts v. Freeman Chamblee/Dunwoody Merger, 1991 53 45 [Citizen Magnet School Proposals], 1990 53 46 [DeKalb County Board of Education], 1990-1991 53 47 [Enrollment], 1990-1992 53 48 [Evansdale Magnet Program], 1993 53 49 [Facilities], 1990-1991 53 50 [M-to-M Materials], 1980-1992 53 51 [Mark Welsh Attorney Notes], undated 53 52 [1994-1995 New Teacher Instructional Orientation for Elementary and Secondary Education Provided as Exhibit 30(a)(z)], 1994-1995 box folder Request box 54 1-2 [Per Pupil Expenditure], 1985-1990 54 3 [Publications], 1991 54 4 [School Attendance Zones], 1990-1991 54 5 [School Floor Plans], undated 54 6 [Staffing Reports], 1989-1991 54 7 [Test Scores], 1992-1993 54 8 [Enrollment Numbers 1988/1989-1991/1992], 1988-1992 54 9-12 [Federal Compliance Reports], 1992-1995
Federal compliance reports are one page reports for each school issued in May which provide the anticipated enrollment numbers for the next September divided by grade and then by race. 54 13 [NAACP], 1989-1993 54 14 [Newspaper Clippings], 1987-1992 54 15-16 [Notes], 1990 Redan High School
About plans to alleviate overcrowding in Redan High School and how those plans might aid or hinder desegregation efforts. box folder Request box 55 1 B/E - Pitts v. Freeman Pleadings, 1990 55 2 B/E - Pitts v. Cherry Elizabeth Andrews, 1980-1983 55 3 B/E - Pitts v. Cherry David Armor, 1985 Questions for Trial, Worksheets, Charts 55 4 David Armor - Correspondence, 1984-1985 55 5 B/E Pitts v. Freeman Data Taken to 8/17/85 Meeting with Armor, 1985 55 6 B/E - Pitts v. Freeman Redan Attorneys' Fees, 1985 55 7 Board of Education (Pitts v. Cherry) Attorneys Notes, 1979, 1984 55 8 B/E Pitts v. Cherry - Attorney's Notes - Appeal - Redan, 1979-1984 55 9 B/E Pitts v. Freeman Attorneys' Notes Re: 8/23/85 Hearing, 1985 55 10 [Transcript Notes], 1984 box folder Request box R.63 2 B/E - Pitts v. Freeman Correspondence, 1985 This folder contains restricted attorney-client privileged records and is open for research on January 1, 2036. box folder Request box 55 11 B/E Pitts v. Cherry - Draft of Appellee's Brief, undated 55 12 [Deposition of Dr. William Stewart Adams], 1984 The deposition focuses on Redan High School, including the process of planning, Adams' planning department, and the process for making enrollment projections. 55 13 [Deposition of Dr. David James Armor], 1984 Armour was the president of National Policy Analysts. The deposition focuses on the results of different desegregation plans and the risk of accelerating white flight from the area around the desegregated schools. 55 14 [Deposition of Dr. Robert Freeman], 1984 Freeman was Superintendent of DeKalb County Schools. The deposition focuses on solutions for overcrowding at Redan. 55 15 [Deposition of Roger Mills], 1984 Mills was a plaintiff in the case. The deposition focuses on Mills' responses to pleadings in the case, particularly overcrowding at Redan, and the history of DeKalb County for the past few years. 55 16 [Deposition of Dr. Michael J. Stolee], 1984 Stolee was the Dean of the School of Education at the University of Wisconsin, Milwaukee. The deposition focuses on his past work creating or critiquing desegregation plans. 55 17 B/E Pitts v. Cherry Brookover Deposition/Mobile Alabama Contains testimony transcripts of expert witnesses Ralph S. Scott, Jr. (University of Iowa), Donald Sale (Virginia Department of Education), and Wilbur Brookover regarding if Mobile Alabama 55 18 B/E - Pitts v. Freeman Deposition of Michael Stolee, Related Cases, 1973-1977 Stolee was the Dean of the School of Education at the University of Wisconsin, Milwaukee. The deposition focuses on his past work creating or critiquing desegregation plans. box folder Request box 56 1-2 B/E - Pitts v. Freeman Deposition of Michael Stolee, Related Cases, 1977-1978 Stolee was the Dean of the School of Education at the University of Wisconsin, Milwaukee. The deposition focuses on his past work creating or critiquing desegregation plans, particularly for Los Angeles. 56 3 Board of Education (Pitts v. Cherry) Documents Given to Plaintiff, 1969-1984 56 4 Redan High Educational Program, 1984 box folder Request box R.63 3 B/E - Pitts v. Freeman Redan, Elementary Site Selection, 1985 This folder contains restricted attorney-client privileged records and is open for research on January 1, 2036. box folder Request box 56 5 Exhibits - Redan - Defendants' Exhibits, 1984 56 6 Exhibits - Plaintiffs' Redan, 1984 56 7 Exhibits - Redan - Selected Defendant's Exhibits, 1984 56 8 Exhibits - Redan - Joint, 1984 56 9 B/E - Pitts v. Freeman Exhibits of 8/23/85 Hearing, 1985 56 10 B/E Pitts v. Cherry Friends of Redan Information, 1983 56 11 B/E Pitts v. Cherry Growth - Residential and Industrial DeKalb County, 1983-1984 56 12 B/E Pitts v. Cherry Lithonia Materials, 1983-1984 56 13 B/E Pitts v. Cherry - Attendance Level Comparison of Desegregation by Rainbow Plan and Redan Addition M to M Plan, 1984 56 14 Pitts v. Cherry (Mobile Units), 1983 56 15 B/E - Pitts v. Freeman Orders and Judgments, 1984-1985 box folder Request box R.63 4 Pitts v. Cherry Redan Issue, 1983-1984 This folder contains restricted attorney-client privileged records and is open for research on January 1, 2035. box folder Request box 56 16 [Pitts v. Cherry Notes], undated 56 17 [Pitts v. Cherry Summarization of Cities in Plaintiffs' Brief], undated 56 18 Pitts v. Cherry Redan/Questions for Witnesses, undated 56 19 B/E Pitts v. Cherry Racial Transition Information, 1969-1983 56 20 Board of Education (Pitts v. Cherry) Rainbow I and II, 1984 56 21 B/E Pitts v. Cherry - Redistricting DeKalb County High Schools & Changes in Racial Composition, 1977-1984 56 22 Research - Redan, 1969-1984 box folder Request box 57 1 Volume IV - Research - Redan, 1984 57 2 B/E - Pitts v. Freeman Seat Availability - Redan, 1977-1984 57 3 B/E Pitts v. Cherry Southwest DeKalb Materials, 1980-1983 57 4 Pitts v. Cherry Stephenson Road School Site, 1976-1983 57 5 B/E Pitts v. Cherry Michael Stolee, 1972 Research box folder Request box 57 6-7 [School Desegregation Cases], 1965-1988 57 8 [Bradley v. Board of Public Instruction of Pinellas County Florida], 1993 57 9 [Board of Education Oklahoma v. Dowell], 1989-1990 box folder Request box 58 1 The Board of Education of Oklahoma City v. Dowell Brief of the DeKalb County Board of Education, 1990 58 2 ["The Dream Long Deferred" by Frye Gailard], 1988 58 3 [Pitts v. Freeman Supreme Court Oral Argument - 1991 Key Precedents], 1991 58 4 Pitts v. Freeman Legal Research of Cases, 1983-1988 58 5 [Center for Census Use Studies Publications], 1976 58 6 [Parent Opinions], 1990 58 7-8 [Research], 1972-1990 [School Information Notebooks]
The notebooks include information like the number of students and faculty by race, notes and maps depicting building use, statistics about the Majority-to-Minority (M-to-M) transfer program, discussion for changes in attendance areas, test scores, economic indicators for students such as housing type and if in the free/reduced lunch program, discipline numbers, and the distance students are bused. box folder Request box 58 9 [Elementary Schools], 1987 box folder Request box 59 1-2 [Elementary Schools], 1987 59 3 [High Schools], 1986 Witnesses
Includes files on expert witnesses and school administrators who would be testifying. The papers include resumes, articles they authored, questions to ask and sometimes the answers, and the lawyers' notes about their work with desegregation or their role in the school system. box folder Request box R.64 3 [Witnesses], 1985-1986 This folder contains student records protected by FERPA and is currently restricted. box folder Request box 59 4-5 [Witnesses], 1984-1987 David Armor, William Clark, Herbert Walberg 59 6 [CVs], 1989 59 7 [For Cross-Examination of Dentler], 1987 59 8 [Witnesses], 1987 box folder Request box 60 1 [Witnesses], 1987
