case, which I am informed and believe was rendered on June 28, 1976.

7. In the summer of 1977, I, in association with other electors and/or parents residing in the SDUSD organized "Groundswell," an unincorporated association, whose objectives include opposing forced busing. I have been President of Groundswell continuously since its formation.

8. I and about 300 other members of Groundswell, during the period from about June 1, 1977, to about October 1, 1977, gathered the signatures of about 22,300 persons from all parts of California, including the SDUSD, in support of a proposed amendment to the United States Constitution called the "Neighborhood Schools Amendment," which included a provision that "(n)o student shall be compelled to attend public school other than the one nearest his residence...."

9. The aforesaid petitions were called to the attention of my United States Congressman, Clair Burgener, for such action as he could take in support of the Neighborhood Schools Amendment then being proposed in Congress for presentation to the States....

15. Since the organization of Groundswell in 1977, I and other members of Groundswell have discussed on numerous occasions the necessity for representation of our interests in this case and inquired of various attorneys the availability of such representation, and throughout this period have been financially unable to pay attorney's fees. We were unable to secure representation in this case until the spring of 1979 when Elmer Enstrom, Jr., our present counsel, undertook representation on a pro bono publico basis that would not obligate those represented, which include a number of minors, for attorney's fees.

Their need for separate representation was obvious, as shown by the following statement by Mr. Lester, in a March 4, 1981, interview