voters; that after enactment of said Act, all but four or five White families, and all but two White voters who formerly re- sided within the old corporate limits resided within the new corporate limits; and that several thousand Negroes who formerly | resided wthin the old corporate limits did not reside within | the new corporate limits, and only approximately eight or ten Negro voters resided within the new corporate limits. No person who resides beyond the corporate limits of the City may vote in any City Elections. 4. That according to the U. S. Census, Advance Report, dated November 8, 1960, the total population of the City of Tuskegee is 1,750. 5. On the basis of the Defendants own admission, Plain- tiffs' allegations remain uncontridicted and unqualified. The ‘conclusion is therefore irresistible, tantamount for all practical purposes to a mathematical demonstration, that the legislation is solely concerned with segregeting white and colored voters by fencing Negro citizens out of town so as to deprive them of their pre-existing municipal vote! Gomillion, et at,| ys. Lightfoot, et al., decided by the U.S. Supreme Court on November 14, 1960, Therefore, on the basis of the law in this case, Plaintiffs are entitled to judgment. Respectfully submitted, Arthur D. Shores | A. G. Gaston Building Birmingham, Alabama Fred D. Gray 34 North Perry st. Montgomery, Alabama Attorneys for Plaintiffs