Lawyer then reviews Enstrom's amici briefs in the Supreme Court, referred to in Chapter Four, and in the California Court of Appeal, referred to in Chapter Six. As to the anticipated points of law, upon the expected facts, in connection with his clients' claims, he drafts a trial brief.

TRIAL BRIEF

I. Statement of Facts. The facts from the official records show that the City School District receives federal financial assistance; that the judicial assignment of students on a racial basis in the District has continued for over 20 years, under a "desegregation" decree arrived at with only the plaintiff-class and defendant District school officials represented; that said school officials are taking no action in the case to terminate such assignments; that there is no longer a majority of any race in the District; that the white students are classified and treated as "majority" students and their numbers are steadily decreasing, while students other then white are categorized in several racial groups as "minority" students, whose numbers are increasing.

The evidence from the official records further shows that the intervening students, of different races and ages starting at age 6, upon enrollment, are assigned pursuant to a court-ordered "desegregation" plan to other than their neighborhood schools because of their race; and that some 28,000 petitions by residents of the District have been filed with the defendant Board objecting to such assignments and seeking the option for students to return to their neighborhood schools.

The evidence from the testimony of Intervenors shows their personal objections to such assignments as District students and their parents of varying races, including those of the same race as those in the plaintiff class; and as taxpayer-electors, respectively.

The evidence further shows (1) by way of the petitions, requests of a substantial number of persons in the foregoing categories for action by the Board in court on the issue of pupil assignments, and (2) the refusal of the Board to act thereupon. This evidence should be admissible for those purposes without serious objection.