Court Filings: District Court, affidavit of Joy C. Springer

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 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, ET AL. v. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. PLAINTIFFS DEFENDANTS INTERVENORS INTERVENORS AFFIDAVIT OF JOY C. SPRINGER STATE OF ARKANSAS) SS) COUNTY OF PULASKI) Comes now the affiant, Joy c. Springer, who submits the following affidavit under oath: A, EDUCATION AND EMPLOYMENT HISTORY 1. I received a BSBA degree in three years from Henderson State University in Arkadelphia, Arkansas in 1977. I was also selected as a member of Who's Who Among American College and University Students in 1977. I was a member of the student Senate and served on one of the first Human Relations Committees at the University. I am currently enrolled at the University of Arkansas at Little Rock pursuing a master's degree in Elementary Education having completed approximately 40 hours. My post graduate work in education was necessitated by my current job 1 I I I I I I I I I I I I I I I I I I I responsibilities and the need to become more familiar w~th educational terminology and concepts. In May, 1995, I was selected as a charter member of Alpha Sigma Lambda Honor Society with a GPA of 3.9. 2. In 1978, I was employed by Allstate Insurance Company as a telephone claims representative in the Little Rock, Arkansas claims office. This office concentrated on handling personal lines insurance claims. Having completed one year of employment, I was recognized as Employee of the Year. over the next several years, I received a number of promotions. Around 1985, I was promoted to Casualty Claim Manager for the State of Arkansas. I was responsible for the training and supervision of claim representatives for the entire state. This training included proper investigation of auto, homeowner and bodily injury claims. I was also a budget manager. I was responsible for reviewing and analyzing claim data (past and present) for use in the preparation of budgets from year to year. The office had a list of goals and commitments for which I was responsible for tracking and reporting to the Regional office. In addition to these duties, I was responsible for the assigning of complaints, which were in the form of lawsuits, to defense attorneys over the entire state for the purpose of providing proper defense to policy holders and the company. I worked closely with our defense attorneys by making periodic contacts with them to monitor the progress of the pending litigation. I was also responsible for maintaining a trial log. I provided monthly 2 I I I I I I I I I I I I I I I I I I I reports to our Regional office. Having worked in a claims office for over ten years, I have extensive training and experience in procedure implementation and compliance, data analysis, time management, file organization, research, and investigations. 3. Most of my actual paralegal training has been on the job for the last five years. However, during my previous employment, many of my paralegal skills were developed. Because of my previous job experience, I was already very familiar with many of the tasks that I currently perform as a paralegal. B, OVERVIEW OF WORK IN THIS CASE 4. Around January, 1990, I went to work full time for John w. Walker, P.A. One of my assignments from Mr. Walker was the Pulaski County school desegregation case. I have attended all of the Court hearings in the Pulaski county school case for the last four years. My work on the school case has included the following tasks: a. reading and review of the Office of Desegregation Monitoring and the three districts' monitoring and status reports, and preparing position papers and memoranda for lead counsel for review and discussion; b. review of all pleadings and orders in this case, and preparing position papers and memoranda for lead counsel for review and discussion; c. overseeing the monitoring activities of the Joshua monitoring team during the 1990-1991, 1991-92, 1992-93 and 1993- 94 school years (see also paragraphs 4 - 11 below); 3 I I I I I I I I I I I I I I I I I I I d. conducting monthly and bimonthly meetings with Joshua monitoring team members to discuss findings during scheduled and unscheduled monitoring visits; e. ensuring that monitoring teams visited every school in the three school districts during the 1991-92 and 1992-93 school years; f. review and discussion of monitoring reports prepared by Joshua team members with lead counsel and team members; g. dissemination of Joshua's monitoring reports to the parties, Office of Desegregation Monitoring and the Court; h. initiating and scheduling of meetings and conferences with the Office of Desegregation Monitoring to secure their monitoring schedules and areas of monitoring priorities for the school year; i. pre-hearing preparations which included interviewing of witnesses, preparation of exhibits, organization of exhibits, file organization and consulting with lead counsel on the issues to be presented at Court; j. abstracting of witness testimony during Court hearings; k. assisting lead counsel with exhibits during court hearings; 1. assisting lead counsel with witness testimony during court hearings; m. representing class members in the Little Rock, 4 I I I I I I I I I I I I I I I I I I I Pulaski County and North Little Rock school districts to ensure implementation of plan provisions for nondiscriminatory practices with respect to discipline and educational placement (see paragraphs 12-18 below); n. contacts with district officials in the three districts to request information with respect to plan provisions and implementation; o. handling telephone calls from class members in the three districts with respect to educational placement, student rights, discipline and plan provisions; p. draft of motions and draft responses to pleadings; q. attending school board meetings and meetings between the parties with respect to plan implementation and proposed modifications; and r. management and organization of the case file, a significant task due to its volume and the need to draw upon its content. C. JOSHUA INTERVENORS' MONITORING REPORTS 4. Since the settlement agreement, the Joshua Intervenors have completed three comprehensive monitoring reports for the years 1990-91, 1991-92 and 1992-93. I spent a considerable amount of time working on these reports and am familiar with the manner in which information was gathered, the content of the reports, and the roles played by the persons involved in preparing each report, whom it was my responsibility to supervise. 5 I I I I I I I I I I I I I I I I I I I 5. The first year of its monitoring, the team visited approximately thirty (30) schools in the Little Rock, Pulaski County and North Little Rock school districts. This report reflected findings at the Incentive schools, in the Little Rock School District, in the following areas: curriculum; student educational plans; discipline; recruitment; parental involvement; biracial committees; classroom findings; interim reports; budget management; staffing; and general concerns. The remaining schools which included elementary and secondary schools were monitored in the areas of: curriculum; discipline; staffing; and general concerns. of these schools. A team of at least three persons visited each One team member met with the principal to ask general questions about student enrollment by race and gender, staff makeup by race and gender, curriculum expectations, parental involvement, discipline expectations, etc. as contemplated by the respective desegregation plans. The remaining team members visited at least one classroom on every grade level, including resource rooms and specialty programs and made contact with the guidance counselor and other support staff in each of the respective schools. This Joshua report and the reports for the next two school years differed from reports later prepared by the Office of Desegregation Monitoring in that they were based upon visits to a more representative number of schools and contained more anecdotal information from students, parents and staff, including information secured during the school visits and in the course of day-to-day work in monitoring the 6 I I I I I I I I I I I I I I I I I I I agreements. Much of the statistical data reflected in the report came from the school's profile. The final report for 1990-1991 consisted of 142 pages of Joshua's findings and recommendations. A copy was initially provided to the central administration of each school district. Later, based upon requests which we received, we provided full copies and/or excerpts to other persons including the representatives of the desegregation offices and individual schools who sought particular portions pertaining to their schools. 6. The other persons who participated in the preparation of the 1990-91 report were Kirke Herman, Evelyn Jackson, and Clementine Rouse, each of whom had a background of teaching in public schools in one of the three Districts; Opal Sims, who taught at the Little Rock Job Corp Center, substituted in the Little Rock School District for a year and monitored federal programs for ACTION, now referred to as Corporation for National Service; and named class representative Lorene Joshua. This report was written by Ms. Sims and me and reviewed by lead counsel, John w. Walker, who had also participated in defining the team's overall approach. 7. During the 1991-92 school year, Joshua's monitoring team members visited every school in the three districts. The team members decided to start with the Pulaski County School District during this school year since Little Rock was monitored first in 1990-91. Afterwhich, North Little Rock was monitored and finally Little Rock. once again, the areas addressed in the monitoring 7 I I I I I I I I I I I I I I I I I I I report were: curriculum; discipline; parental involvement; staffing; and general areas of concern. The areas addressed in the Incentive school report for 1990-91 were discussed again. The same general approach was followed whereby a team visited certain schools with at least one monitor holding a conference with the principal and the other team members making visits to the other classrooms as previously indicated. In this report, the team members felt it necessary to indicate to the schools their areas of strengths along with their areas of concerns. Statistical data was gathered from the school's profile and from the school's principal. The team once again felt that it was important to include anecdotal findings from students, parents and staff members, drawn both from the monitoring visits and other work. The final report for the 91-92 school year was completed and filed with the Court on or about June 5, 1992 by LaRhonda Pondexter and myself. The document contained 328 pages of Joshua's findings for over 119 schools that were visited. It was shared with all parties and others, in a manner similar to the previous year. The report indicated that there was a substantial amount of noncompliance by each of the districts regarding their commitments to address achievement disparities, discipline disparities, integrated parental involvement, student assignments, integrated staffing, overrepresentation in special education and underrepresentation in gifted programs and advanced placement classes. 8. In addition to the co-author, LaRhonda Pondexter, the 8 I I I I I I I I I I I I I I I I I I I persons who participated in the second year monitoring efforts were Kirke Herman, Evelyn Jackson, Lorene Joshua, Clementine Rouse, and a second new team member, Delores Sykes, a retired teacher from Rockefeller Incentive School of the Little Rock School District. This report was also reviewed by lead counsel, John W. Walker. 9. The last comprehensive report by the Joshua Intervenors was completed and filed with the Court on or about June 27, 1993. It consisted of 396 pages of the team's findings and recommendations to the three school districts, following visits to every school in the three systems. This report followed the same format as the two previous reports. The report reeked with continued noncompliance regarding desegregation commitments. Joshua Intervenors followed the same approach as the previous years in disseminating the report. 10. The third report was written by Deborah Parker and myself. Other team members were Kirke Herman, Clementine Rouse, Delores Sykes, and Lorene Joshua. Lead counsel, John w. Walker again reviewed this report. 11. Following each report, we received responses and feedback to what we had written. Persons who called and provided written responses were the assistant superintendents for desegregation in the Little Rock and Pulaski County districts (multiple occasions); principals from all of the districts (multiple occasions); members from the Incentive School Parent Council and Biracial committees; patrons of the Districts; as 9 I I I I I I I I I I I I I I I I I I I well as representatives of newspapers and television stations who publicized on several occasions our findings of noncompliance and recommendations. A number of the school representatives thanked us for undertaking this work and stated that they would address the concerns in areas such as deficiencies in the Incentive school program, discipline, staff racial composition, student assignments, enrollment in gifted programs, participation in extracurricular activities, etc., which the reports by Joshua Intervenors identified. D. ASSISTANCE TO CLASS MEMBERS FACING DISCIPLINE 12. Each plan requires that discipline be carried out in a manner that is free of racial discrimination. See LRSD Plan, pages 33-34, PCSSD Plan, pages 73-76, and NLRSD Plan pages 41-42. Nevertheless, data reported for each system, during the period after approval the settlement, has repeatedly established that black students, particularly black males, are disciplined more frequently and severely than white students. During the 1990-91 school year, lead counsel, John W. Walker assigned me the task of representing class members threatened with discipline by one of the three systems, and their parents, in order to secure for them the benefits of the relevant plan's protection against racial discrimination in discipline. As shown by the attached summary of my work, this has been one of my significant activities since that time. 13. In the course of this work on discipline, I have represented at hearings a total of approximately 120 class 10 I I I I I I I I I I I I I I I I I I I members. I have also assisted a significant number of class members experiencing discipline problems by a telephone call to the student's teacher, principal, or central office administrator. These discipline problems have also been resolved through appeal at the hearing officer level for the Little Rock School District, the Discipline committee level for the Pulaski County Special School District and the Assistant Superintendent for Student Affairs level for the North Little Rock School District. I have assisted class members in all three school districts with approximately 75-80% concerning Little Rock schools. I have attended hearings at among other the following schools: Little Rock Elementary schools - Mabelvale, Washington, Franklin, Mitchell, Rockefeller, Ish, Rockefeller, Martin Luther King, Fulbright, Jefferson, Woodrow, Fair Park, Badgett, Baseline, Geyer Springs; Little Rock Junior High schools - Horace Mann, Dunbar, Southwest, Cloverdale, Henderson, Mabelvale, Pulaski Heights and Forest Heights, Cloverdale, and Mabelvale; Little Rock High Schools - central, Fair, Parkview, Hall, J.A. Fair and McClellan; North Little Rock schools - North Little Rock East and West campuses, Ridgeroad and Lakewood Junior Highs, Boone Park, Bellwood, and Rose City elementary schools; Pulaski County Elementary schools - Fuller, Bates, Sylvan Hills, Sherwood, Jacksonville, Homer Atkins, Baker, Lawson, Landmark, and Crystal Hill elementary schools; Pulaski county Junior High schools - Jacksonville North and south Junior High, Fuller, Sylvan Hills, Northwood, and Oak Grove; Pulaski County High 11 I I I I I I I I I I I I I I I I I I I schools - Jacksonville, North Pulaski, Sylvan Hills, Mills and Oak Grove. Approximately 75% of the cases in which I represented students, class members were not excluded from school as had initially been proposed. Joshua Intervenors also used in another way the information learned in representing these class members. When there appeared to be a problem of racial discrimination in a particular school, we notified the Superintendent or Assistant Superintendent of the particular district. In some schools, as a result of my work, I have detected that class members are treated more fairly in the discipline process, although, there remains a need for improvement. 14. It is clear to me that racial discrimination affects the discipline process in these three school systems in a variety of ways. For example, there are instances of teachers and administrators being insensitive to the fact that a student acted out as a result of racial harassment, advocating exclusion from school and not proposing to utilize in-school suspension or other non-exclusionary placement, proposing harsh discipline for trivial conduct, etc . E. OTHER ASSISTANCE TO CLASS MEMBERS FACING DISPARATE TREATMENT 15. Each of the districts also requires that class members receive educational opportunities that they have previously been denied but for racial discrimination such as participation in extracurricular activities, participation in gifted and talented and advanced placement programs, etc. See LRSD Plan pages 39-40; 12 I I I I I I I I I I I I I I I I I I I NLRSD Plan pages 39-40; and PCSSD Plan pages 69-70. These plans also require that class member placement in special education programs be free of racial discrimination. See LRSD Plan pages 111-123; NLRSD Plan pages 16-23; and PCSSD Plan pages 44-52. 16. However, data reported from each of the three districts since the settlement agreement continue to show that black students are placed in special education programs more frequently and at a higher rate than white students. Black student participation in extracurricular activities such as Honor Society, Beta Club, Student Government Association, etc. remained predominately white. In addition, white students continue to be placed in advanced placement and gifted and talented programs at a higher rate than black students. As a result of these statistics, personal and telephone conferences with class member parents, lead counsel, John w. Walker also assigned me the task of participating in conferences with parents of students with concerns about educational placement. 17. I have participated in over 50 conferences over the last five years regarding educational placement. I have assisted class members in all three districts with approximately 75-80% concerning Little Rock schools. I have attended conferences in Little Rock Elementary schools - Mabelvale, Washington, Franklin, Mitchell, Rockefeller, Ish, Rockefeller, Martin Luther King, Fulbright, Jefferson, Woodrow, Fair Park, Badgett, Baseline, Geyer springs; Little Rock Junior High schools - Horace Mann, Dunbar, Southwest, Cloverdale, Henderson, 13 I I I I I I I I I I I I I I I I I I ~I Mabelvale, Pulaski Heights and Forest Heights, Cloverdale, and Mabelvale; Little Rock High schools - Central, Hall, J.A. Fair and Parkview; Pulaski Elementary schools - Fuller, Bates, Sylvan Hills, Sherwood, Jacksonville, Homer Atkins, Baker, Lawson, Landmark, and Crystal Hill elementary schools; Pulaski County Junior High schools - Jacksonville North and South, Fuller, Sylvan Hills and Oak Grove; Pulaski county High schools - Mills, Sylvan Hills, North Pulaski and Jacksonville; and North Little Rock schools - North Little Rock East and West campuses, Ridgeroad and Lakewood Junior High schools and Bellwood and Boone Park Elementary schools. I would say in 90-95% of the conferences held, the parent was satisfied with the outcome of the educational placement. Joshua representatives have employed the knowledge and information gained in these conferences to alert district administrators to perceived problems of racial discrimination. 18. In addition to the work previously outlined above, I had personal and telephone conferences with parents of class members to provide assistance and direction regarding student assignments, transportation, and general concerns about school operations. over the past five years, I have had over 500 conferences of this nature. I would estimate that approximately 85-90% of these had satisfactory results in that a resolution was reached satisfying the parent and class member. 19. Finally, I have also been instructed by lead counsel to conference with black staff members in all three Districts to 14 I I I I I I I I I I I I I I I I I I I listen, assist and give direction regarding problems they perceive as violative of the Consent Decree herein. A number of these conferences have addressed disparate treatment of student and staff relating to the overall school operation. However, many have to do with perceived racial discrimination by the Districts with respect to their individual employment. I have had conferences with approximately 20 staff members in all three Districts. I have had conferences with staff from the following schools in Little Rock: Rockefeller, Wakefield, Garland, Mitchell, Gibbs, Franklin, Mabelvale, Parkview, Central, Hall, Pulaski Heights, Forest Heights, Southwest, Cloverdale and Mabelvale. I have given other assistance to staff member in the following schools in North Little Rock: West and East campuses, Alternative school and Ridgeroad Junior High school; and Oak Grove High, Sylvan Hills Elementary and Junior High, Fuller Junior High and Mills High schools in Pulaski County. l, HOURS CLAIMED, HOURLY RATE AND OTHER INFORMATION 20. Attachment 1 to this affidavit denotes 3169.1 hours which I have worked on this matter from June, 1990 to October 31, 1995 including time for preparation of this fee statement. I have worked closely with Mr. Robert Pressman and Mr. John Walker since September, 1995 regarding the compilation and preparation of this motion, memorandum, affidavits, fee petitions, expense statements and other related documents. With respect to the time expended by me regarding this massive undertaking, my actual time 15 I I I 1 I I I I I I I I I I I ,, I I I records reflect that I have worked for more than 12 hours a day from November 8, 1995 to November 20, 1995 including Saturdays and Sundays. The time expended during this period of time is in excess of 150 hours. Because I had already reviewed and organized many of the documents used for the preparation of this motion, I only make claim for ~ hours. I believe this request is reasonable given the voluminous nature of this case file. No time is being claimed for orientation of Mr. Pressman. My time statement excludes time for the following matters related to this case: a. the Little Rock Rezoning case; b. fees already awarded by this court regarding the ADE matter in 1993; and c. fees related to the PCSSD reorganization in 1993. 21. I compiled from the check registers maintained by Mr. Henry Hall, office manager for John W. Walker, P.A. information showing the following total payments reimbursed to me for mileage costs and other monitoring expenses in the case of LRSD v PCSSD in the years 1991, 1992, 1993, 1994, and 1995. The totals are: 1991 - $1669.29 1992 - $1523.97 1993 - $75.00 1994 - $1208.75 1995 - $265.00 Total - $4742.01 These payments are evidenced by the "checks stubs" maintained by Mr. Hall for the following checks. 1991 12022 12028 12253 12509 16 627.00 50.00 94.16 222.64 I I I 1 I I I I I ,, I I I I I I I I I 12573 173.64 12668 201.85 12994 300.00 $1669.29 1992 1797 66.19 1817 220.69 1879 1000.00 1935 53.28 2343 100.00 2369 150.00 $1523.97 1993 13599 75 . 00 $75.00 1994 1268 116.15 1439 92.60 15811 1000.00 $1208.75 1995 16457 65 . 00 16463 200.00 $265.00 The records also reveal a payment to Kirke Herman for expenses on February 8, 1995 in the amount of $100.00 (check number 14871). I have also compiled from the check register of Mr. Henry Hall other expenses related to this case such as witnesses fees and copying of the docket. These payments were as follows: ~ !:;hegt Number Pumose Amount 9/16/95 17121 copy of docket $ 60.00 6/23/95 16819 witness fee 40.00 3/3/94 14981 expert witness 215.00 2/15/94 14921 copy of transcript 39.00 'l'otal - $354.00 17 I I I I I I I I I I I I I I I I I I I 22. I am also in a position, based upon my work, to estimate the amount for facsimiles, postage, and copying costs which we have incurred for this case from the period of 1991 through October 1995, a period of 58 months. It is as follows: COPYING *average of 1500 copies per month multiplied by 58 months equals 87,000 copies; *cost at .15 cents per page equals $13,050.00; conservative estimate of cost for copying in absence of records equals $6500.00 (43,333 copies or 747 copies per month, 1 1/2 packages of copy paper). conservative estimate of cost for copying of Joshua monitoring report for years 1991, 1992, and 1993 would be 1000 pages at 10 copies (includes copies for Court, parties and file) equal 10,000 copies *cost of 10,000 copies at .15 cents per page is $1500.00 Total costs for copying - $8000.00 FACSIMILES average of 100 pages of faxed material per month multiplied by 58 months equals 5800 copies; cost at .10 cents per page equals $580.00; average of 1 case of facsimile paper per month at a cost of $33.18 by 58 months equals $1924.44 *conservative estimate of cost for faxing documents totals $2504.44 in absence of records equals $1250.00 Total fax costs - $1250.00 POSTAGB average of 25 letters to the eight counsel (two to LRSD and one for file) of record per month multiplied by 58 months 58 months equals 11600 letters; 18 I I I I I I 1 I I I I I I I I I I I I average cost of postage per letter@ .55 equals $6380.00 *conservative estimate of cost for postage totals $3190.00 in absence of records Total postage costs $3190.00 23. My other work in the Walker firm includes personal injury claim handling, interviewing of potential clients for other cases being handled by the office, conferring with potential clients regarding other school matters across the state, and other duties as assigned by Mr. Walker for which the office currently bills my time at the rate of $50.00 per hour. It is the practice in the Little Rock area to bill paralegal time separately. 24. In the course of my employment at the Walker firm, I have also worked on the following cases: Robert Webb, et al v Missouri Pacific Railroad (employment discrimination); McFadden v Arkansas state Hospital (employment discrimination); Lou-Ease Simmons v Augusta School District (school case/tracking); Judy Smith v Harvest Foods (employment discrimination); Gay Rusk v Stuttgart School District (employment discrimination); Richard Day and Calvin Hollowell v Randy Johnson (employment discrimination); Angela Piggee v Hope School District (employment discrimination); Willie Ashford v The City of !fmburg, et al, (police brutality) and Gloria Leapheart v city of Morrilton (employment discrimination) to name a few. I was awarded a fee of $45.00 per hour in the case of McFadden, et al. y Arkansas State Hospital, Civ. No. LR-C-78-153 as recently as April, 1995 19 I I I I I ., I I I I I I I I I I I 1 I for my work. 23. My work as a paralegal in this case minimizes the fee liability of the districts by reducing the lawyer time expended on the case. I have read the foregoing affidavit and it is true and correct to the best of my knowledge SPRINGER I f1~UBSCRIBED AND SWORN to before me this ?,.{day of 1/vb-{ , 1995. NOTARY PUBLIC MY COMMISSION EXPIRES: Ci/ 17 l'-1.0~ 20 I I I I I I I ,, I I I I I I I I I I I J IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT V. NO. LR-C-PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL. ACTIVITY STATEMENT OF JOY CHARLES SPRINGER DATE ACTIVITY TIME 6/28/90 Conference with JWW regarding Pulaski .5 County School case 6/28/90 Reading and review of Pulaski County 1.5 school settlement agreement 6/29/90 Conference with JWW regarding Incentive 3.5 school hearing; Preparation for hearing; review of Incentive school plan 6/30/90 Prehearing conference with JWW; Hearing 8.0 before Judge Wright re: Incentive school hearing; abstract of witness testimony 8/5/90 Review of LRSD desegregation plan 3.5 8/21/90 Review of LRSD desegregation plan 4.0 9/8/90 Review of PCSSD desegregation plan 4.0 10/15/90 Review of NLRSD desegregation plan 2.5 1/5/91 Conference with JWW re: implemetationn 3.0 of desegregation plan and discussion re: assistance Joshua can provide to parties re: implementation and identification of problem areas c:\wpdos\jcs.stmt 1 PLAINTIFF DEFENDANTS AMOUNT I I I I I I I I I I I , , I I I I I I I 1/6/91 1/8/91 1/9/91 1/10/91 1/11/91 1/11/91 1/14/91 1/15/91 1/24/91 1/25/91 1/30/91 2/4/91 2/18/91 c:\wpdos\jcs.atmt Conference with JWW re: plan 1.0 implementation, assistance to District, and identification of problem areas Pre-meeting conference with JWW; 1.9 meeting school district officials and lawyers regarding modifications to desegregation plan; took notes; post meeting conference Meeting with school district officials and 6.0 lawyers regarding plan modifications; post meeting conference with JWW Meeting with school districts officials and 5.5 lawyers regarding plan modifications Conference with PCSSD attorney, SJ, to 3.0 discuss plan modifications; travel to his office; parking $4.25 Preparation of memorandum to JWW re: 2.0 meetings with respect to plan modifications Discussion of monitoring instrument with 2.5 JWW; preparation of same Preparation of monitoring instrument 4.0 Preparation for hearing re: Aersospace 4.5 proposal; telephone confemce with CJ re: implementation procedure; telephone with PCSSD,NLRD, LRSD re: implmentation procedure; preparation of exhibits; conference with JWW re: trial strategy Hearing before Judge Wright re: 1.0 Aerospace grant proposal Continued review of Aerospace proposal 2.0 Continued review of Aerospace proposal 2.0 and LRSD desegregation plan Deafted proposal for monitoring activities 6.5 and instrument for Joshua monitoring team 2 I I I I I' I I I I I I I I I I I I I I 2/25/91 2/26/91 2/26/91 2/27/91 2/27/91 2/27/91 2/28/91 2/28/91 c:\wpdos\jcs.stmt Conference with Joshua team members to 3.0 discuss monitoring activities and instrument; updated monitoring instrument; discussed LRSD schools to be monitored; conference with JWW Used personal vehicle for travel to Mitchell 1.5 Incentive school to monitor Incentive school program with Joshua team members; conference with principal and visted classrooms Used personal vehicle for travel to lsh 1.5 Incentive school to monitor Incentive school program with Joshua team members; conference with principal and visted classrooms Used personal vehicle for travel to Garland 2.0 Incentive school to monitor incentive school program; conference with principal and visited classrooms Used personal vehicle for travel to 1.5 Stephens lncentve school to mointor incentive school program; conference with principal and visted classrooms Used personal vehicle for travel to 1.5 Rightsell Incentive school to monitor incentive school program; confemce with principal and visited classrooms Used personal vehicle for travel to 2.0 Rockefeller Incentive school to monitor incentive school program; conference with principal and visited clasrooms Conference with team members to discuss 2.5 results of monitoring visits and discussion of monitoring instrument for Incentive schools 3 I I I I I I I I I I I I I I I I I I I 3/1/91 3/4/91 3/4/91 3/5/91 3/5/91 3/6/91 3/6/91 3/7/91 3/7/91 3/7/91 c:\wpdoa\jcs.stmt Conference with team members to further 1.5 discuss findings from incentive school visits and formulate draft report on findings Used personal vehicle for travel to lsh and 2.3 Mitchell Incentive schools to observe extended programs Preparation of draft report re: first week's 2.5 observations and findings at Incentive schools Used personal vehicle for travel to LRSD 1.5 elementary schools -Geyer Springs and Cloverdale for discussion and inspection of construction at these school with administration. Court approval? Preparation of report regarding visits to 1.3 elementary