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Virginia, and is bascd solecly upon their race or color,

"2, The plaintiff Alston and all of thc members of the
plaintiff assoclation and all other Negro teachers and principnls in
public schocls in the City of Norfolk arc tcachers by profcssicn and
arc specially trainecd for their calling. By rules, regulaticns,
practice, usage ond custon of the Comnonwealth acting by and through
the defendants as 1ts agents and agencics, the plaintiff Alston and
all of the ncmbers of the plaintiff associaticn and all other Negro
tcachers and principals in the City of Norfolk arc being dcnicd the
equal pfoﬁééff@ﬁ“BT“fﬁE’IﬁﬁE‘Iﬁ“tﬁﬁt”ﬁﬁiély‘bwaﬁﬁSEh of their rmcc,
and color thcy arc being denicd conpoensation fron public funds for
their scrviccs as toachers equal to the compensation provided fron
public funds for and being pald to whitc teachers with cqual quall-
pications and cxpericnce for cquivalent sorvices pursuant O rulcs,
regulations, custon and practice of the Commonwealth acting by and
through its agents and agenciles, the School Board of the City of
Norfolk and the Superintendent of Schools of Norfolk, Virginia.

"13, Plaintiff, Molvin O. Alston, has been anploycd as a

rogular malc teocher by the docfendants sincc Septenber, 1935, and 18