integration plan devoid of racial balancing. An order providing for such a plan would allow it to focus primarily upon providing quality education to all its students and meet constitutional standards.
 

I then prepared presentations which summarized the objections to the plan spelled out in the foregoing two briefs to be made in behalf of Groundswell by its founder and president to the Board at its scheduled meetings.

On May 23, 1996 Mr. Lester presented objections to the Board which he reiterated in a second presentation on May 30 as follows:

I, Larry K. Lester, Acting President of Groundswell, an association of persons opposed to school assignments of students on the basis of race, on May 23rd presented Groundswell's objections to the following aspects of the present integration program as being racially discriminatory and not being in compliance with the Constitution:

1. The “assignment of students to particular seats and to particular classes solely because of race.”
2. The basic rule “that the percentage of students (in classrooms) must not deviate more than plus or minus 20% from the proportion of White students in the school.”
3. The drawing (gerrymandering) of school boundaries to implement a plan to assure racial / ethnic balance not “in excess of 50 percent White versus other ethnic groups” in schools.
4. The granting of priorities in the Choice Program to VEEP students to attend schools from which local neighborhood students have been displaced by the gerrymandering of school boundaries.

A summary of these objections (copy attached) was given to each Board member at the May 23rd Board public meeting.

I also called attention to petitions, with 47 signatories,