because of the practice, usage and custon conplaineG 01 1N Pedfpl-cepid
11 of ‘this' com-‘m by 'thé_.aporat:.on of the dishe’rilminatory salar;
schedule described in paragraphs 16 and 17 of this complaint the
plaintiffs have becn, are, and unless relicf shall be grantcd DY this
Honorable Court as hereinafter prayed, will continue to be denled,
solely by reason of race and color the opportunity to receive a higher
salary equal to that pald to any white tcachers sinilarly situatcd.
w16, Puresmant to the policy, custon and usage sct out in
paragraph 12 the dcfendants acting as agents and agenciecs of the