Court Filings: District Court, declaration of Robert Pressman and affidavit of Austin Porter Jr.

The transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors. I I I I I I I I I I I I I I I I I I I Little Rock Sch. Dist. v. Pulaski County Spec. Sc. Dist. Number 1 Civil Action No. LR-C-82-866, E.D. Ark., Western Div. DECLARATION OF ROBERT PRESSMAN Robert Pressman swears under penalty of perjury that the following is true and correct: A. Employment in Civil Rights Division (1.) Following my graduation from Columbia Law School in June 1965, I worked as an attorney in the Civil Rights Division, U.S. Department of Justice, from August 2, 1965 ' through July 31, 1970. The Division enforced civil rights laws concerning voting rights, access to public facilities and public accommodations, school desegregation, equal employment opportunity, and freedom from mistreatment by police personnel. My work at various times involved each of these areas. It encompassed giving guidance to the Federal Bureau of Investigation on investigations of possible civil rights violations and compiling factual material and analyzing complex fact patterns, as well as legal research. (2.) For roughly the first two years of my tenure in the Division, I was assigned to work on problems arising in the northern part of Mississippi. During this period, I frequently travelled to Mississippi and, among other things, made appearances in the Carroll County school desegregation case. I also investigated the status of school desegregation in other systems, including Lee County, Pontotoc County, Tunica County, and the City of Corinth. In 1967, the Division was reorganized and my work shifted to 1 I I I I I I I I I I I I I I I I I I I Illinois. There, I developed facts concerning school segregation in School District 151 of Cook County, Illinois. The Department's suit against that district was its first northern case. I participated in the trial. See United States v. School District 151, 286 F. Supp. 786, 787 (N.D. Ill. 1968); 301 F. Supp. 201, 205 (N.D. Ill. 1969). My Illinois work also included school segregation issue in Cairo, East St. Louis, and Madison County, Illinois. (3.) In 1969, the Division was again reorganized, this time along subject matter lines. I was assigned to the education section. From October 1969 through my departure from the Division at the end of July 1970, I worked principally on Alabama school desegregation issues, particularly on Lee v. Macon County Board of Education, a statewide case involving 100 local districts, as well as state officials. Efforts were underway in this period to secure implementation of plans satisfying the standards of Green v. County School Board. I prepared written comments on issues arising in more than 30 Alabama districts and appeared frequently before the three-judge court (Judges Richard T. Rives, Frank M. Johnson, and H.H. Grooms). I also appeared before Judge Johnson in the separate Montgomery County school desegregation case and prepared for the Department briefs in two appeals from the decisions of the three-judge court in the Lee case. See, for example, Lee v. Macon County Board of Education, 448 F.2d 746, 747 (5th Cir. 1971). (4.) On December 15, 1969, I received a Certificate of Award for outstanding work, in the Attorney General's Twentieth Annual Awards Ceremony. Four of the Division's ninety attorneys were given this award at that time. 2 I I I I I I I I I I I I I I I I I I I B. . Employment at the Center for Law and Education (5.) In August 1970, I began working at the Center for Law and Education (CLE), a component of the federally-funded program of legal services for low-income persons, administered since 1975 by the Legal Services Corporation. As the "national back-up center'' on education issues for the entire legal services program, the Center's principal role was to promote throughout the program strong representation of clients experiencing education problems. The work consisted of providing advice to legal services personnel on particular client problems; conducting training programs; writing publications and articles; engaging in administrative advocacy; and participating as co-counsel in some cases. My employment at the Center ended as of September 15, 1995, due to lay off, because the Congress chose to eliminate funding for national support programs like CLE. (6.) In 1972, upon its filing, I began working on the Boston school desegregation case as co-counsel for the plaintiff class of Black parents and students. My involvement has continued to the present, although the case is largely inactive with only a few orders remaining in place. See, for example, Morgan v. Hennigan, 379 F. Supp. 410, 414 (O.Mass. 1974) (liability ruling) and Morgan v. McDonough, 540 F. 2d 527, 528 (1st Cir. 1976) (argued appeal in which the court affirmed the placing of the operation of a high school in receivership). Through the years, I had the occasion in Morgan to address the issue of an award of attorneys fees and costs in a number of instances. Indeed, Judge Garrity presently has under submission a request that CLE receive an award for 547 hours of my work in Morgan in the period from October 1988 through June 1993 at a rate of $200 per hour. There were also a number of times through the years when the inquiries from 3 I I I I I I I I I I I I I I I I I I I legal services attorneys and other advocates to which I responded concerned fee awards. (7.) In the 1970's I also did some work in the Detroit school desegregation case, Bradley v. Milliken, and more than 1000 hours of work on behalf of the plaintiffsintervenors in the Omaha school desegregation case, United States v. School District of Omaha. See, for example, 521 F.2d 530 (wrote brief for successful appeal with the court's opinion reflecting to a substantial degree the factual statement in the brief). In addition, particularly in the earlier years of my tenure at the Center for Law and Education, legal services attorneys and other advocates asked questions about school desegregation issues in a number of instances, to which I responded. (8.) During the 1970's, I played a role at CLE in the development of a racial discrimination theory ultimately employed successfully in securing a delay in the Florida program of denying standard high school diplomas to students failing a "competency test." See Debra P. v. Turlington, 474 F. Supp. 244 (M.D. Fla. 1979), affd, 644 F.2d (5th Cir. 1981). In the Debra P. litigation, I participated briefly in the trial (due to an illness in the family of a CLE colleague) and wrote a portion of the trial memorandum setting forth a theory accepted by the courts ( denial of standard high school diploma based upon competency test result perpetuated earlier intentional discrimination against black students who began their educations in segregated and unequal elementary schools). (9.) In 1986, I wrote two memoranda on racial discrimination claims for use in the legal services program. (a) The first, focusing on racial discrimination in school discipline and curricula, contained the following headings: ''Typical Problems," "Gathering Information About a Discrimination Problem," ''The Legal Bases of Racial Discrimination 4 I I I I I I I I I I I I I I I I I I I Claims" (including constitutional and Title VI claims), "Other Material re Disparate Discipline," ''Material Regarding Disaimination in Curriculum," and "Remedial Principles." (b) The second memorandum is titled "Discriminatory Allocation of Resources within a School District" (14 pages). I first used this document in a training program for legal services attorneys in Philadelphia, Pennsylvania in 1986. (10.) I participated during my tenure at CLE, as a trainer or lecturer, in a minimum of 40 sessions on education issues for legal services workers, parents, and\or students. One such session in the late 1980's for legal services attorneys concerned ways to monitor consent deaees and other judgments in institutional refonn cases. I prepared for this event a lengthy memorandum summarizing and organizing, according to topic, a large number of reported and unreported decisions relevant to the topic of monitoring a decree. C. Work on the Ayers Case (11.) In January 1987, the North Mississippi Rural Legal Services Program asked me to join their staff members providing representation to the named plaintiffs and the plaintiff class in the case then styled Ayers v. Allain, Civil Action No. 4:75CVOO9-B-O, Northern District of Mississippi. Ayers concerns the nature of the obligation of Mississippi officials to eliminate racial disrimination and segregation from the operation of the Mississippi system of public universities. I have played an active role in the case since that time. My work in Ayers through March 1995, totalled in excess of 6,000 hours, and involved, inter alia, framing and responding to discovery requests; taking depositions; identifying and preparing exhibits; preparing exhibit lists and other materials required as 5 I I I I I I I I I I I I I I I I I I I part of the standard pre-trial submission; participating in settlement efforts; making an opening statement; presenting and aoss~xamining witnesses and otherwise participating in two lengthy hearings; 1 preparing proposed findings of fact and conclusions of law; preparing appellate briefs; arguing before a panel of the Court of Appeals for the Fifth Circui~ as well as that court sitting en bane, 2 and supporting the efforts of my brother and sister co-counsel. Currently, some of my time is spent working on an appeal from the district court's decision on remand, Ayers v. Fordice, 879 F.Supp. 1419 (N.D. Miss. 1995). D. Court Appearances (12.) During the course of my legal career, I have made appearances in the following federal courts: M.D. Ala., S.D.Ala., M.D. Fla., S.D. Fla., N.D. Ill., D. Mass., N. D. Miss., E.D. Mich., D. Neb., D. N. H., and D. S. Car.; Court of Appeals for the First, Fifth and Eleventh Circuits (filed briefs and argued); Court of Appeals for the Eighth Circuit (filed briefs); United States Supreme Court (filed briefs). E. Work in this Case (13.) In September 1995, John W. Walker requested me to assist him and other persons in his firm to prepare a comprehensive fee application for the post-judgment monitoring phase of this case. Attachment One to this declaration, which is incorporated 1 The first hearing in 1987 consumed approximately 25 trial days. In 1992, the United States Supreme Court held that the lower courts had employed the wrong legal standard in dismissing the case, articulated the correct standard, and remanded for further proceedings. see united states Y, Fordice, 112 s.ct. 2727. The hearing on remand in the trial court consumed 44 trial days in 1994. 2 see Ayers v, Allain, 893 F.2d 732 (5th cir. 1990); Ayers y, Allain, 914 F.2d 676, 677 (5th Cir. 1990) (en bane) (argued in each instance). 6 I I I I I I I I I I I I I I I I I I I herein by reference, sets forth my time and activities in working on this project. Because it was necessary for me to learn matters already known by Mr. Walker and his staff, and the nature of some of the work, the motion seeks an award for 120 hours, only 50.2 percent of the time which I actually worked on this very extensive undertaking. I believe that my "learning curve" regarding the case was less than it would have been, had I not had extensive experience regarding school desegregation, racial discrimination, monitoring, and fee award issues. (14.) The amount sought for my time is $175 per hour. The following factors support the reasonableness of this hourly rate: (a) the higher rates awarded to John W. Walker by Arkansas district courts as shown by his affidavit, filed with the joshua motion; (b) the approval of rates of $200 per hour to counsel in this case and the Kansas City school desegregation case by the Court of appeals for the Eighth Circuit during the mid- 1980's, as shown by that court's McDonald decision cited in the Joshua memorandum in support of the motion; (c) the rates for Little Rock law firms shown in Arkansas Business, November 13, 1995, at 25; (d) the fact that the Center for Law and Education seeks an award of $200 per hour for my time in the Boston school desegregation case for work in the period from 1988 through 1993; and (e) the fact that the Center seeks an award of $250 per hour for the more than 6000 hours which I worked in the Mississippi higher education case in the period from 1987 to 1994 (with any award to be used by the Center for work on behalf of low income persons). I dedare under penalty of perjury that the foregoing information, and the information set forth in the attachment, which is incorporated herein by reference, are true and correct. 7 I I I I I I I I I I I I I I I I I I I Executed on this :)J)day of tJ ~ , 1995. Robert Pressman STATE OF ARKANSAS ) 1 )ss. COUNTY OF hJ})1tu ) SUBSCRIBED AND SWORN to before me this c20 day of 1995. Notary Public My Commission Expires: 9/;7/~? l I 8 I I I I I I I I I I I I I I I I I I I IN THE UNITED SATES DISTRICT COURT OF ARKANSAS EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, ET AL. v. LR-C-82-866 PUIASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE W. KNIGHT, ET AL. ATTACHMENT ONE PIAINTIFFS DEFENDANTS INTERVENORS INTERVENORS SCHEDULE OF HOURS OF ROBERT PRESSMAN DATE ACTIVITY TIME 9/18/95 Discuss fee 3.00 petition with JWW and JS seeking relevant records, such as docket and ruling of 12/1/92; identify substantive decisions on case; identify pertinent Eighth Cir. & Ark. fee decisions (MQQon~lg, HslcQissi, Jeffer, etc.); study rel. parts of Schwartz treatise on fees I I I I I I I I I I I I I I I I I I I 9/19/95 9/20/95 9/21/95 9/23/95 9/24/95 9/25/95 9/26/95 9/27/95 Begin to draft motion; Schwartz treatise (paralegals, rates, fees for fee petition); call to Norman Chachkin ~ status of fees for appeals; read prior LR, vs, PCSSD decisions Study Del. Vallev decision and cases cited on monitoring; identify issues to discuss with JWW Review case docket Read PC settlement agreement & study parts bearing on fees & make notes Work on memorandum in support of award of fees for post-judgement monitoring Work on memorandum Work on fee memorandum and motion for award of fees; study docket; study treatise (fees for fee petition and rates) Motion for fees 2.40 1.00 1.00 1.50 7.50 3.00 5.50 0.25 I I 9/28/95 Work on topics for 4.50 JS affidavit and I discuss with JS; work on motion for fees (areas I covered in LR plan); examine transcript 2/24/94 .I n JWW role; work on topics for JWW aff. and fee memorandum I 9/29/95 Work on memorandum 5.50 I 9/30/95 Work on fee memo; 6.50 read Tr. 6/7/94 I and make notes I 10/1/95 Work on fee memo; 7.00 complete Tr. of 6/7/94 and make notes I 10/2/95 Work on Part II. 6.50 of memo; work on I motion in support of fees (attachments) I 10/10/95 Read Duran case 0.16 I (10th Cir.) 10/11/95 Work on memo; 0.80 I research cases on allocation among defendants, cost I of investigators and post-judg. mon. I I I I I I I I I I I I I I I I I I I I I I I 10/12/95 10/14/95 10/15/95 10/16/95 10/17/95 10/18/95 Identify tasks to get petition filed; research on waiver issue; work on motion (attachments) Read Tr. of 1/24/94 & make notes Work on list of tasks (3 pages) Work on RP affidavit for fee petition; speak to JS i:g JWW affidavits in other cases & securing transcripts Work on RP affidavit; research Eighth Cir. and Ark. cases on scope of settlement/release ; identify and read cases on interim fees; read cases on fees for post-judgement monitoring; topics for JWW affidavit; work on ideas~ para. IV-B of settlement Read Tr. 1/24/94 and make notes; work on "to do list"; work on memo in support of motion 1.50 0.50 LOO 2.75 7.66 3.80 I I 10/19/95 Work on memo. , RP 3.25 I affidavit 10/20/95 Read Tr. 1/25/94 3.25 I and make notes 10/21/95 Read transcripts 7.75 , 1/25/94 & 6/28/94 & make notes; work on memo; work with I JS on aff. (Joshua mon., discipline work); review JS aff. I 10/22/95 Read transcripts 6.25 I 6/28/94, 6/29/94, 3/29/94 and 7/28/94 and make notes; work on I memo; work on motion (attachments) I 10/23/95 Discuss "to do 1.50 list" for fee I petition & issues presented with JWW & JS; call to CH I n fee petition I 10/24/95 Determine JWW 3.00 hours as reflected in transcripts; review bills I submitted by other counsel in post-settlement period; I help gather & organize time records for JWW firm I I I I I I I I I I I I I I I I I I I I I I I 10/26/95 10/25/95 10/27/95 10/30/95 10/31/95 11/1/95 Review transcripts at ODM for the period 1/25/91 to 8/3/92 to identify time and role for JWW and other members of the firm and make notes Substantive work on case: work with JS on motion and memorandum n LRSD faculty and administrators Review JS aff. Organize data from review of transcripts of hearings, including members of the firm participating in each hearing: issues to discuss with JS Work on memorandum in support of fees: work on motion (attachment): work on ideas re Para. IV-B of settlement Read decisions on interpreting settlement: plan needed steps in call to JS & work on JWW hours week of 10/23/95 2.25 2.33 0.33 1.0 7.0 1.0 I I 11/4-5/95 Make notes for 2.0 I section of brief addressing PC settlement agreement (9/89) I 11/7/95 At law library, do 4.25 research on I interpreting contracts (Restatement, I Eighth Circuit and Ark. cases); write part of memo on I contract principles, including reading decisions I 11/8/95 Work on 3.75 I memorandum; compile RP hours on fee petition for affidavit; I review JS compilation of hours I 11/9/95 Organize materials 8.50 n: reconstruction I of JWW time ., 11/10/95 Organize materials 9.00 n: reconstruction of JWW time; check RP schedule of I hours and JS schedule I 11/11/95 Work on 9.50 reconstruction of JWW time with JWW 1 and JS; check JS schedule of hours I I I I I 11/12/95 Work on 10.25 I reconstruction of JWW time with JWW and JS; calculate number of hours I worked by counsel for NLRSD after settlements I 11/13/95 Work on 9.75 reconstruction of I JWW time with JWW and JS; work on memo in support of I fees 11/14/95 Work on 9.50 I reconstruction of JWW time with JWW and JS; interview I Opal Sims u: her work at Walker law firm; brief law student on two 'I projects; discuss Mark B. time with him I 11/15/95 Work on 10.25 reconstruction of I JWW time with JWW and JS; work on Opal Sims and R. I Eddington affs.; prepare motions for extension; I work on summary chart I 11/16/95 Work on 10.25 reconstruction of JWW hours with JWW I and JS I I I I I 11/17/95 Compile hours 9.50 I worked by Friday firm: work on motion (attachment): work I on topics for JWW affidavit: review litigation I expenses: read cases on fees for fee petition: review JS I attachment I 11/18/95 Work on 11.25 memorandum: confer with WAB I 11/19/95 Work on 14.75 memorandum: work I on motion and attachments: confer with JWW n: strategy: work ,, on topics for JS aff. : work on expenses and H. I Hall aff.: identify remaining steps; work on BP I aff. 11/20/95 Work on BP aff.: 4.25 I work with JWW and JS on JWW hours; work on memo and ,, attachments to motion I 238.98 Hours TOTAL I I I I .I , , , , I I I I .I ,, , :, t I t I I I' I I IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, ET AL. V. NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL. LORENE JOSHUA, ET AL. AFFIDAVIT OF AUSTIN PORTER JR. PLAINTIFFS DEFENDANTS INTERVENORS Comes the affiant, Austin Porter Jr., submitting the following affidavit under oath: 1. I graduated from the University of Arkansas at Little Rock in the fall of 1982 with a major in criminal justice. During the spring of 1983, I was awarded one of two Winthrop Rockefeller Scholarships to attend law school at the University of Arkansas at Little Rock (UALR) School of Law. I enrolled at the UALR School of Law during the fall of 1983. I graduated from the UALR School of Law on May 18, 1986. On August 25, 1986, I was admitted to the practice of law before the Bar of Arkansas. I have also been admitted to practice before the United States District Court, Eastern and Western Districts of Arkansas. 2. Upon completion of law school, I went to work for Central Arkansas Legal Services (CALS), where I handled cases such as domestic relations, consumer, real estate and landlord tenant. I worked at CALS from August, 1986 until May 5, 1989. I then worked at Walker, Roaf, Campbell, Ivory & Dunklin. While at this firm, I handled personal injury litigation and criminal matters. I also continued to handle consumer matters. I joined 1 I I I 1, I I t I I I I ,, I I ,, I ,, I I the firm of John W. Walker, P.A. on September 2, 1991, and have been involved in employment discrimination cases and voting rights cases. 3. The professional associations that I hold memberships are: American Bar Association, Pulaski County Bar Association and the W. Harold Flowers Law Society. I served on the Board of Directors of the Pulaski County Bar Association during 1990 and 1991. I served as chairman of the Law Day Committee for the Pulaski County Bar Association. 4. Some of the cases that I have been involved in are: Tammie McFarlin, et al. v. Newport Special School District, 980 F.2d 1208 (8th Cir. 1992); Harrison v. Moore, United States District No. PB-C-91-0468, Johnny Whitfield, et al. v. Forrest City School District, fil..lll, United States District Court No. H-C-88-86, Adams v. Hartwick, United States District Court No. LR-C-86-747, Petty v. Scan, United States District Court No. LR-C-91- 324, Green v. Bell, 308 Ark. 473, 826 S.W.2d 226 (1992), Simmons on Behalf of Simmons v. Hooks, 843 F.Supp. 1296 (ED.Ark. 1994), Gloria Leapheart v. The City of Morrilton, et fil., United States District Court No. LR-C-91-696, Sherri Betton v. Sears. United States District Court No. LR-C-91-852, Willie Ashford v. The City of Hamburg, Arkansas, et al., United States District Court No. 93-1032, Tarar Porter v. Carolyn Staley. United States District Court No. LR-C-94-8, Richard Day and Calvin Hollowell v. F. G. "Buddy" Villines, fil..fil., United States District Court No. LR-C-94-849. 5. The fee that I am requesting in this case is $130.00 per hour which is reasonable and commensurate with my experience and qualifications. The rate is comparable to that of other attorneys with my experience, and working in Little Rock, Arkansas who are 2 I , , I 'I I 'I ' I I I I I I (' ,, t ,, 'I I involved in this type of litigation or in general practice. (See the affidavits of Mark D'Auteuil and Jerome Green attached herein as Exhibits "A" and "B", which were recently submitted in the case of Gloria Leapheart v. The City of Morrilton, et al., United States District Court No. LR-C-91-696). 6. I was recently awarded an hourly rate of $130.00 for the work that I performed in the case of Gloria Leapheart v. The City of Morrilton, et al., United States District Court No. LR-C-91-696 and Willie Ashford v. The City of Hamburg, Arkansas, et al., United States District Court No. 93-1032. 7. The total time that I am seeking to be compensated for in this case is 175.50 hours. 8. The total time of 175.50 hours is a conservative but reasonable submission based upon my time records which were prepared contemporaneously to the performance of the work. I have attached a true and accurate account of the hours that I have expended in representing the Joshua lntervenors and their interest in this case. The total amount of time being billed is submitted upon careful review of my records, and consultation with co-counsel, and necessary reductions of hours have been made in order to avoid unproductive and duplicative work. 9. My time record is being submitted for hours that I have expended for work directly related to this case (68.50) and for hours that are related to this case and came about as a result of students who were referred to our office either by the school districts and/or class members; the total hours for these cases are 1 07. 00 hours. 10. As a result of our representation of the Joshua lntervenors as well as our 3 I I , , 'I I I I I I I I I I' I l ,I t ,, , I I monitoring of the schools in Pulaski County, we are often asked to take cases whereby a student has been disciplined or has been denied some right in school due to race or color. The cases listed below (with the exception of Brandon Nunnely) involved students who were recommended to be suspended and/or expelled from school due to having been charged with a criminal offense. During the school hearings where we would be representing the child, we often argued that it is fundamentally unfair to suspend and/or expel a child for merely being charged with a criminal offense. Furthermore, these students had criminal charges filed against them by the state. A. Cynthia Mahomes/Brandon Nunnely - I represented Brandon Nunnely in a case against the Pulaski County Special School District. Brandon is a handicapped child, and wanted to attend a special Dyslexia school. The PCSSD did not want to pay for this school. A hearing was held, and ultimately the Special Law Judge ruled that the district did not have to pay for this expense. B. Carla Jordan - a student at North Side Jr. High. Ms. Jordan was charged with Battery 2nd, Disorderly Conduct, and Attempted Assault. Ms. Jordan was accused of attacking Nolan Ricks and was charged with Battery 2nd, a class D felony. The Battery charge was thrown out of court, and she was found delinquent on the Disorderly Conduct and Attempted Assault charges. C.. Remal Brown - a student at Sylvan Hills High School. Remal was charged with Criminal Attempt to Commit Rape - Class A felony, Terroristic Threatening - Class D felony, and Battery in 3rd Degree - Class A misdemeanor. Remal was accused of trying to rape a student at Sylvan Hills High School during school hours. This juvenile was 4 , , 1 I I -I I' I 'I I ,, \ t I I ,I ,'I I II ultimately found delinquent on these charges. D. Richard Ridgel - a student a Joe T. Robinson. Richard was charged with Battery 2nd for striking a teacher during a fight with another student. The juvenile accidently hit the teacher during the fight. The juvenile plead no contest to these charges. E. Kenneth Clay - a student at McClellan High School. This case received a great deal of publicity; the paper reported that a gang fight occurred at school. Kenneth is charged with inciting a riot, a class D felony. Trial on this case is set for trial on January 3 & 4, 1995. This statement is true and correct to the best of my knowledge, records, information and belief. STATE OF ARKANSAS) )ss. COUNTY OF LONOKE ) Austin Porter Jr. ,8 SUBSCRIBED and SWORN to before me, a Notary Public, on this dOday of !Ver. , 1995. 5 MY COMMISSION EXPIRES: q I I l I 2-0o,:s 6 ,, I t t I I 1 \ I ,, I ,, 1' I I ,I. ' I II I I In reference to: DATE 09/04/91 12/18/91 12/19/91 01/12/92 06/30/92 08/03/92 07/05/93 07/06/93 07/07/93 07/08/93 04/19/94 04/20/94 ACTIVITY STATEMENT -AUSTIN PORTER JR. Little Rock School District, et al. v. Pulaski County Special School District, et al.; Lorene Joshua, et. al.; Katherine Knight, et al. (lntervenors) ACTIVITY HOURS Court appearance before the 8th Circuit of Appeals regarding the proposed plan modifications 3.5 School Hearing before Judge Wright on the financing aspects of the desegregation plan and interdistrict schools 6.5 School Hearing before Judge Wright on the financing aspects of the desegregation plan and interdistrict schools 8. 0 School Hearing before Judge Wright on proposed plan modifications 8.0 School Hearing before Judge Wright the incentive schools 7.5 School Hearing before Judge Wright regarding the LRSD budget 8.0 Reading over school budget - Preparation for the budget hearing 6.5 Reading over school budget - Preparation for the budget hearing 3.5 School hearing before Judge Wright on the LRSD and PCSSD budgets 8.5 School hearing before Judge Wright on LRSD and PCSSD budgets 8.5 Met with client Richard Ridgel 2.0 Court appearance on behalf of Richard Ridgel 1.0 1 I I DATE ACTIVITY HOURS ' 04/28/94 Met with client Richard Ridgel to discuss trial strategy 1.5 ' 06/07/94 Court appearance on behalf of client Richard Ridgel 1.0 09/23/94 Went to juvenile court to copy Ridgel file 1.5 I' 09/25/94 Read Ridgel file 1.0 I 09/28/94 Met with client Ridge; discussion of trial strategy 1.5 09/29/94 Court appearance on behalf of Richard Ridgel 2.5 I' 10/26/94 Met with client R. Brown and parent S. Williams 2.0 discussed case I 10/27/94 Read over Brown file 1.5 ' 11/07/94 Received client's letter; re: school actions .5 I 11/07/94 Spoke with client over the telephone re: case and strategy .5 11/07/94 Spoke with Dr. Patrick Smith, M.D. re: R. Brown .3 I 01/20/95 Met with client K. Clay and parent to discuss case 1.0 t 02/08/95 Conference with Joy Springer re: B. Nunnerly matter .5 02/09/95 Read over Nunnerly file 1.0 I 02/13/95 Read over Nunnerly file 1.0 I 02/14/95 Met with Client C. Mahomes; discussed case 2.5 ii , 02/15/95 Worked on trial brief for hearng on behalf of Nunnerly 8.5 02/16/95 Reviewed evidence and documents in file re: Nunnerly 1.0 t 02/17/95 Dictated letter to Client Mahomes re: hearing .2 \I 02/19/95 Legal Research re: Nunnerly hearing 2.5 I 2 , , I I' DATE ACTIVITY HOURS I 02/20/95 Hearing preparation and Hearing re: Nunnerly matter 11 .5 I 02/22/95 Spoke with Ms. Mahomes re: Nunnerly hearing .2 02/24/95 Hearing preparation re: Nunnerly matter 1.5 I 02/24/95 Hearing re: Nunnerly matter 5.5 I 03/01/95 Court appearance on behalf of R. Ridgel 1.5 03/13/95 Worked on Findings of Fact re: Nunnerly matter 6.5 , , 03/14/95 Worked on Findings of Fact re: Nunnerly matter 6.5 I 03/22/95 Met with client K Clay and parents; discussed hearing strategy 1.0 I 03/23/95 Court Appearance - LR. Municipal Court on behalf of K Clay 1.5 05/05/95 Went to juvenile court to pick up subpoenas and prepared for I service re: R. Brown matter 2.5 11 05/15/95 Spoke with witnesses re: R. Brown matter 1.5 I 05/17/95 Went to juvenile court to copy file re: Brown matter 2.0 t 05/25/95 Preparation for hearing re: R. Brown matter 4.5 05/26/95 Hearing re: R. Brown matter 4.0 I 06/15/95 Spoke with clients' sister and aunt re: hearing of R. Brown .5 ' 06/15/95 Dictated letter to client re: hearing of R. Brown 1.5 I, 07/17/95 Met with client C. Jordan 2.0 07/17/95 Read over Jordan file 1.0 ' 07/19/95 Court Appearance - Pulaski County Circuit Court on behalf of K Clay 2.0 I 07/19/95 Spoke with the case coordinator for Judge Warren re: C. Jordan.25 I 3 I I I DATE ACTIVITY HOURS I 07/20/95 Received letter from case coordinator re: C. Jordan matter .1 I 08/02/95 Spoke with client and Dr. Smith re: R. Brown matter .5 08/07/95 Court appearance on behalf of R. Brown 1.0 ' 09/19/95 Prepared Motion for Discovery re: K Clay matter 1.0 I. 09/21/95 Copied file in Prosecuting Attorney's Office re: K Clay matter 2.0 09/21/95 Read over clients' file re: K Clay matter 3.5 I' 09/21/95 Drafted Motion for Severance re: K Clay matter 2.5 I 09/22/95 Court Appearance on behalf of K Clay 1.5 09/22/95 Spoke with Larry Jegley re: K Clay matter .2 I 10/30/95 Dictated letter to client C. Jordan .25 I 11/14/95 Hearing in Juvenile Court on behalf of C. Jordan 1.7 I t TOTAL HOURS EXPENDED 175.2 II I I ' 11 I 4 I, This project was supported in part by a Digitizing Hidden Special Collections and Archives project grant from The Andrew W. Mellon Foundation and Council on Library and Information Resources.