Court Filings: District Court, affidavit of John W. Walker

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 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, ET AL. V. LR-C-82-866 NORTH LITTLE ROCK SCHOOL DISTRICT, ET AL. MRS. LORENE JOSHUA, ET AL. KA THERINE W. KNIGHT, ET AL. AFFIDAVIT OF JOHN W. WALKER STATE OF ARKANSAS ) )ss. COUNTY OF LONOKE ) PLAINTIFFS DEFENDANTS INTERVENOR$ INTERVENOR$ Come now the affiant, JOHN W. WALKER, who submits the following affidavit under oath: A. Educational and Professional Qualifications 1. I graduated from Arkansas AM&N College in Pine Bluff, Arkansas in 1958 with a major in Sociology. In 1960, I was awarded a John Hay Whitney Opportunity Fellowship which I used to obtain a Master's Degree from New York University in Education (Human Relations) in 1961. In 1961, I enrolled in the Yale University Law School from which I received my law degree in 1964. At Yale Law School, in 1964, I was a finalist in the Thunnan Arnold Appellate Moot Court Competition. I have studied further at Fisk University (the Race Relations Institute) and at many legal training seminars which focused upon the subject of civil rights law in particular. 1 I I I I I I I I I I I I I I I I I I I 2. In 1964, I was admitted to practice before the Bar of Arkansas. Subsequently, I was admitted to, and still practice before, the United States Supreme Court, the Court of Appeals for the Eighth, Fifth, Eleventh, and Tenth Circuits, the United States District Court, Western District of Texas, and the United States District Court, Eastern and Western District of Arkansas. 3. I completed a legal training internship in New York City with the NAACP Legal Defense and Educational Fund (LDF) in September, 1965. In 1965, I opened a private general law practice in Little Rock which emphasized civil rights law. In 1968, Norman Chachkin (now of the LDF) and I opened one of the first integrated law firms in the South. That law firm has continued to be operated on an integrated basis since that time although it has undergone several name changes. My own work continues to emphasize civil rights legal activity. 4. I hold membership in the American and National Bar Associations, and the W. Harold Flowers and Pulaski County Bar Associations. From 1976 to 1982, I was a member of the Arkansas Board of Examiners. I have served as a member of the Federal Rules Advisory Committee of the Eighth Circuit Court of Appeals. I am a member of the Board of Directors of the LDF in New York. 5. The following is a partial listing of major cases where I have been lead counsel: Employment Paxton v Union National Bank, 688 F. 2d. 522, 574 (8th Cir. 1982); Maney v Brinkley Municipal Water Works, 802 F 2d. 1073, 1076 (8th Cir. 1986); Rogers 2 I I I I I I I I I I I I I I I I I I I v International Paper Co., 423 U.S. 809 (1975); Powell v Georgia Pacific Paper Company, Civ. Nos. 73-C-1 and E.D. 73-C-3 (Ark. 1993); Williams v Anderson, 562 F 2d. 1081 (8th Cir. 1977); Clark v Mann, 562 F 2d. 1104 (8th Cir. 1977); Parham v Southwestern Bell, 433 F 2d. 421 (8th Cir. 1970); Robinson v Klassen, Civ. No LR-C-73-301 (E.D. Ark. 1981); McFadden v Arkansas State Hospital, Civ. No. LR-C-78-153 (E.D. 1989; 1994); Taylor v Jones, 653 F 2d. 1193 (8th Cir. 1981); Hollowell v Gravett, Civ. No. LR-C-86-600 (E.D. Ark. 1989); and Perryman v Johnson Products, 698 F 2d. 1138 (11th Cir. 1983); Hollowell and Day v. Randy Johnson, E.D. Ark., October 30, 1995 .. Education Clark v Board of Education, 705 F 2d. 265 (8th Cir. 1983); Dowell v Oklahoma City Board of Education, 890 F 2d 1483 (10th Cir. 1989); Arvizu v Board of Education of Waco, Texas, 296 F 2d. 1309 (5th Cir. 1974); Kemp v Beasley, 389 F 2d. 178 (8th Cir. 1972); Raney v Board of Education of Gould, Arkansas, 381 F.2d 252 (8th Cir. 1967); Kelley v Altheimer, 378 F 2d. 483 (8th Cir. 1967); Little Rock School District v Pulaski County Special School District , 839 F 2d. 1296 (8th Cir. 1987), cert den., 102 L. Ed. 2d. 146 (1988); Smith v Board of Education of Morrilton, 365 F 2d. 770 (8th Cir. 1966); and Sherpell v. Humnoke School Dist. No. 5.; Rusk v. The Stuttgart School District,_ F.Supp. _, E.D. Ark. (1994). Housing 3 I I I I , I I I I I I I I I I I I I I Williams v Matthews, 499 F. 2d. 819 (1974). Criminal Justice Winters v Beck, 407 F 2d. 125 (8th Cir. 1969). Public Accommodations Daniel v Paul, 395 U.S. 298 (1969). Voting Rights Sherpell v Humnoke, __ F.2d. __ (8th Cir. 1989); Harvell v Ladd, 978 F. 2d. 226 (8th Cir. 1992); Harvell v Ladd, __ F. 3d. __ (8th Cir. 1994); Williams v City of Texarkana. __ F. 3d. ___ (8th Cir. 1994). 6. I have served as Chairman of the Board of the Arkansas Opportunities industrialization Center (OIC), the Center for Law and Education (Cambridge, Mass.). and the Leadership Roundtable (Little Rock, Arkansas). In 1968, I was a member of the Arkansas Constitutional Revision Study Commission. In the early 1970's, I was a member of the Land Use Study Commission of the Southern Governors Conference. I have served as a member of the Supreme Court Committee on Legal Education. I have spoken or lectured at several annual meetings of the National Bar Association; the American Bar Association; other bar associations; many public colleges and many high schools regarding many subjects but primarily upon the subject of Civil Rights Law. I have also received numerous awards for my representation of civil rights causes and cases. B. Prior Work in School Desegregation Litigation in Pulaski County 7. I have a very large amount of experience concerning issues of racial discrimination and segregation in the Little Rock, North Little Rock, and Pulaski County 4 I I I I I I I I I I I I I 1 I I I I I school systems. My activities began in 1965 with the preparatory work and the filing of Clark v. Board of Education of Little Rock, in which I was lead counsel. This case was a successor to Cooper v Aaron which had become inactive. Desegregation litigation concerning the North Little Rock Schools, in which I was also lead counsel, was initiated in 1967 in the Graves case. The Clark case was very active through 1982, when the case of Little Rock School District v Pulaski County Special School District was filed. There were many appeals in Clark. I also became involved in desegregation litigation in the Pulaski County Special School District in approximately 1969 in the Zinamon case which was settled. The North Little Rock case also involved considerable time through the early 1980's. The level of activity in Zinaman did not approach that of the other two cases. I filed for black citizens a motion to intervene in LRSD v PCSSD, which was pressed, and denie~ j'fler the district court ruled on behalf of the LRSD regarding liability. On appeal, the Court of Appeals recognized the right of the Joshua intervenors to represent the black parent and students in the three districts. This led to the renewal of my active role in school desegregation litigation in Pulaski County, which has continued to the present. C. 8. Involvement in This Case I was an active participant throughout the negotiations in 1988 and 1989, which produced the five agreements and the settlement of this case. 9. I have done some work on this case, in its post-judgment phase, on the majority of days since June, 1990. My work has included, inter alia, the following activities: 5 I I I I I I I I I I I I I ,, I I I I , (a) negotiating a series of modifications to the agreements which resolved this case, with the revised agreements denominated by the parties the "May 1991 Plan"; (b) negotiating a series of stipulations to resolve issues arising in the postjudgment phase of this case; (c) preparing for, attending, and participating (by argument, as well as crossexamination and presentation of witnesses), in approximately 55 hearings scheduled by the court (not including the hearings concerning the return of Arkansas officials as defendants and the election case); ( d) raising in the hearings many significant issues not raised by other parties; (e) calling problems/issues to the attention of the attorneys for the defendants and school officials, in each of the three districts, on many occasions; (f) meeting with counsel and school officials, with ODM representatives present at times, to gather information, to present concerns, and to seek to resolve issues regarding compliance with and modification of the court-approved agreements; (g) responding to proposals for plan modification in accordance with the courtapproved procedure (see Pulaski County Plan, at 104-05); (h) attending community meetings to brief the plaintiff class on the agreements, to answer questions and to discuss particular issues, and, generally, to secure the views of the class members on the direction of the case; (i) informing ODM of the concerns of the Joshua lntervenors and responding 6 I I I I ,, I I I .I I I I I I I I I I I to questions posed by ODM personnel; 0) overseeing the work of Ms. Joy Springer, members of my firm, and other persons who have represented the Joshua lntervenors in the post-judgment phase of this case; (k) overseeing the work of Ms. Springer and the other members of the Joshua monitoring team who prepared and disseminated to the parties, ODM, the Court and the public for a period of three school years, three lengthy reports setting forth findings and recommendations regarding the three school districts; (I) assisting individual class members - by responding to inquiries and more formal representation - who were experiencing problems regarding discipline, placement, and other matters; also assisting school district staff members who were experiencing problems; (m) studying the large volume of correspondence, pleadings, reports, court orders, and other documents generated in the post-judgment phase of this case, as well as internal memoranda prepared by Ms. Springer for my use; (n) determining the need for particular correspondence and pleadings and their content; ( o) drafting correspondence and pleadings; (p) speaking in public forums to support the desegregation plan; and (q) resisting efforts to undermine the plan and to diminish the constitutional rights involved. 7 I 1 I I I I l1 I I I I I I I I I I I I 10. The documentation of my work and that of Ms. Springer for the post-settlement period shows a very considerable emphasis on assisting individual class members and school staff. This emphasis is a result of my many years of experience in this type of litigation, as well as the experiences of others, discussed in articles and when counsel litigating these kinds of cases convene. It has been recognized that what have been termed "second generation school desegregation problems" have often worked to defeat the improved educational opportunities for black youth, which are the goal of school desegregation. We have, therefore, worked to apply provisions of the plans to particular instances of discipline, program placement, grading practices, participation in extracurricular activities, hostile faculty and staff attitudes, and adverse treatment of staff. It is our goal that each time we work in a particular school, we not only help the class member ( or staff member) involved, but also help to educate the school staff to be more sensitive to those we represent in the future. 11. It is apparent from our time records that much of the work which we have had to do in the post-settlement period has been attributable to the inadequate implementation of the Court-approved settlements, particularly by the Little Rock School District. The Court has often recognized these compliance problems. See, for example, the Court's 8- page written statement of March 19, 1993, identifying many problems and areas of noncompliance; see also; Tr., March 29, 1993, at 17 ("[The LRSD Board] must be driven by this plan. The plan has to drive their actions and that has not been happening clearly."); at 19-20 ("But [the LRSD defendants] drag their feet, and they don't have a plan in place to focus and they don't have a process in place to focus on what needs to be done to fulfill their obligations and I have waited long enough and I'm tired of waiting."); 8 I 1- I I I I I I I I I I I I I I I I I Tr., June 7, 1994 ('Well, saying that you can do this and saying that you will do it is not going to be enough in this courtroom any more. You're going to have to say specifically in some detail what you will do, when you'll do it, whom you'll contact and what have you."); Tr., June 29, 1994, at 54-62 (court notes inadequacies in LRSD, in budgeting practices, program evaluation, communication with the Joshua lntervenors, and community involvement). 12. We saw the settlement agreements in their totality as designed to promote desegregation, much stronger educational outcomes for black pupils, and real efforts to eliminate harsh practices affecting black youth. We perceived these agreements to require actions bespeaking the equality of all citizens. We anticipated good faith, competent implementation of the agreements. However, we have often been disappointed. We have, therefore, used every available advocacy technique, in an effort to hold the defendants to the agreements which they made, to improve their performances. We provided three detailed monitoring reports to the systems. Our goals included strengthening cooperation and helping the defendants to identify the barrirs to full equality for black students. We offered models to produce effective results in the Incentive Schools. We have taken the lead, in dealing with the State, to protect (and increase) the financial resources available to the districts. We have been conscientious in terms of preparation for and participation in the budget (and other) hearings. We have sought to promote improved budgeting practices and to prevent the waste of resouces. We have opposed harmful budget cuts. We have emphasized that considerations of equity and equality in the provisions of resources require that some new facilities be opened in the black community ( opposing the pattern of merely closing schools in our class members' neighborhoods). The intervening class does not accept "one way'' remedies - and we 9 I I I I I I I I I I I I 1, I I I I t I have made that point. We have addressed issues concerning staff hiring and placement, transportation, participation in extracurricular activities, and many others. Ms. Springer and I have been available to assist class members day after day, as evidenced to our affidavits. This description and others in my affidavit are, of course, only a brief description of our efforts and accomplishments. D. My Hours In the Post-Settlement Phase of This Case 13. The attachment to this Affidavit contains 97 pages, documenting my work in the post-judgment phase of this case. While the identification of my work is the product of a reconstruction of my efforts, I am confident that it is accurate. This is so because a variety of sources, containing overlapping information, including my memory, as well as records and court documentation were used to identify particular tasks. The identification of 1,798 hours, approximately 6.4 hours per week, is very conservative. I am certain that my actual time on this case greatly exceeded the number of hours claimed. 14. One basis for my confidence that the time claimed for me is conservative is a comparison of this time with the time for which counsel for the LRSD, the NLRSD, and the PCSSD have been paid in the post-settlement period . Analyses performed in my office, utilizing documents secured by invoking the State Freedom of Information Act, show the hours worked by opposing counsel to be as follows: LRSD NLRSD PCSSD 1995 (1-8/95) 1995 (1/4/95) 1995 (March) 1029.5 hrs. "230.75 hrs. "29.8 hrs. 128.7 per mo. *57.7 per mo. 10 I I' I I 'I I II I 1 I I I I I ' I I I f I 1994 1994 1994 (6-19/94) *1774.3 hrs. *668.75 hrs. *148.4 hrs. *147.9 per mo. *55.7 per mo. Note: Other bl/,. show ,,.yment for WOiie throughout the period since December 1990, but not the hours claimed. 1993 (8 mo.) 1993 *1465.5 hrs. *55.0 per mo. *122.1 per mo. (1-2, 7-12/90) 1992 1992 (11 mo.) *1256.5 hrs. 555.75 hrs. *104.7 per mo. 50.5 per mo. 1991 1991 (10 mo.) *1529 hrs. 814.25 hrs. *127.4 per mo. 81.4 per mo. 1990 (4-12/90) 1990 (5 mo.) *206.75 hrs. 372.5 hrs. 74.5 per mo. TOTAL TOTAL TOTAL 7261.55 hrs. 3301.8 hours Incomplete While this time does include some time which we have excluded in the current motion - for example, the time involved in seeking to require state officials to comply with the settlement agreement - it is to be noted that my work is directed to all of the school 11 I I J I -1 I, I ' I I I' I I I , , , I I I districts to a greater extent than counsel representing each district, E. The Reasonable Hourly Rate and Related Matters 15. The following factors establish, I believe, that the rate sought for my work in the post-settlement phase of this case, $250.00 per hour, is a reasonable rate: (a) I was described by Circuit Judge Richard Arnold in Taylor v. Jones as a member of the bar of the ''first rank." In 1995, in an order awarding attorneys' fees, Judge George Howard, Jr. of this Court wrote: ''The Court notes that Walker is one of the most preeminent civil rights attorneys in the State." See McFadden v. Arkansas State Hospital, C.A. No. LR-C-78-153, at 3. (b) I have very extensive experience in school desegregation litigation, both generally and in Pulaski County, as detailed in paragraphs 1 through 7 of this Affidavit. (c) I regularly charge fee paying clients $250.00 per hour when they are able to pay that rate. In most of the cases in which I have represented prevailing parties, I have settled my fee requests with the losing party at my regular rate in order to avoid the additional cost of litigating and preparing fee petitions. (d) On September 7, 1994, John Haley of the firm of Arnold, Grobmyer & Haley signed an Affidavit for use in the case of Leapheart v. City of Morrilton and Carl Gipson, C.A LR-C-91~96. Mr. Haley stated that his rate for "a practice consisting mostly of commercial, corporate and bankruptcy law'' was then $225.00 per hour. He supported that rate for my work in Leapheart, which was for the period from October 12, 1992 through September 13, 1994 as "consistent with fees charged 12 I 1' J I I I I I 1 I I I 'I I' I :I I by (him) and other attorneys in Central Arkansas with similar lengths of practice, standing, expertise, and ability'' (at 1-2). (e) I was awarded $175.00 per hour for work in the McFadden case, concerning employment discrimination, by Judge Howard in 1989. In the 1995 Order in McFadden to which I have referred, Judge Howard increased the rate for my work to $225.00 per hour (at 3). This year, in Ashford v. City of Hamburg. El Dorado No. 93-1032, I was awarded $225.00 per hour by the Honorable Harry Barnes. In that case, involving police brutality, Attorney John Hall reviewed my affidavit and time record for the defendant and agreed that $225.00 per hour was a reasonable hourly rate for my services. (f) The publication Arkansas Business sets forth in its November 13, 1995 issue, the results of a survey of 12 Little Rock law firms regarding their "hourly fee range[s]." Of 10 firms willing to furnish information, one identified a top rate of $250.00 hour, i.e., Jack, Lyon and Jones, and two identified top rates of $225.00 per hour. See Attachment Two to this Affidavit. (g) The counsel for the school districts have been paid regularly throughout the post-settlement period. In contrast, any comprehensive award to our firm will be delayed. (h) The volume of the work in this case and the unpredictable demands on my time have limited my ability to represent fee paying clients. (i) We seek the vast majority of the amount sought from the LRSD. Granting the requested rate would, hopefully, provide an inducement for those defendants 13 I I I I I I I I I I I I i 1 I I I l , , I, ' t i I I t I t I I to improve the poor quality of the district's compliance with the Court-approved settlements, about which the Court has frequently commented. 16. It is the practice in this market to bill a fee-paying client separately for the time worked by a paralegal. Our firm currently bills fee-paying clients $50.00 per hour for the work of Joy Charles Springer, given the level of her experience and the quality of her work. It is also worth noting that the assignment of considerable work to Ms. Charles, in this case, greatly reduces the defendants' liability for fees. 17. I have expended more than $150,000.00 in out-of-pocket monitoring costs over the course of this Settlement Decree. This includes time for Ms. Springer and the others who assisted with the undertaking. Her time is not separatelyclaimed except byher affidavit and time statement. Monitors Clementine Rouse (now deceased), Evelyn Jackson, Delores Sykes and Kirke Heman, are former school teachers in schools within this county. Debbie Parker is a former paralegal for Woodson Walker & Associates in Little Rock. She is a graduate of UALR. LaRhonda Pondexter is a graduate of Hendrix College. Pondexter and Parker worked frull-time in monitoring and in writing the report filed by Joshua herein. To my knowledge, both live outside the city; hence we only claim the actual payments made to them for reimbursement. The claim for monitors, except for Springer does not include their 1995 receipts (i.e., payments which I made to them for monitoring work). I expressly reserve the right to make a later claim for this time and/or expense. I seek reimbursement for the time and expense as verified by Ramsey Eddington, C.P.A. in the amount of $96,812.81. 18. Our motion seeks an apportionment of the award of fees and costs among 14 I I I I J I I t 'I j '' I I t 'l f t I the school districts as follows: Little Rock School District (75 to 85), Pulaski County Special School District (15 to 20 percent), and North Little Rock School District (5 to 10 percent) (total to be 100 percent). This reflects my assessment of the time spent litigating against the three systems, including reviewing information and filings, and their relative culpability. E. The Negotiation of and the Content of the Settlement Agreement 19. In the years 1988 and 1989, I represented the Joshua lntervenors in a series of negotiation sessions with counsel for the other parties which ended with the five agreements ultimately approved by the Court of Appeals for the Eighth Circuit and this court. These agreements set forth desegregation plans for the LR, NLR, and PCSSD systems, an interdistrict plan, and the financial commitments of the state. Other participants in these discussions were counsel for the parties: Herschel Friday, Chris Heller and, Jerry Malone, for the LR school district; Alston Jennings and Sam Jones for the PCSSD," and Steve Jones and Phil Lyon, for the NLRSD; Walter Smiley, a local businessman, and Skip Rutherford, also a local businessman who was then a member of the Board of LRSD. 20. In the course of the discussions we addressed relief of benefit to the Joshua lntervenors and other students, which had definite financial implications for the districts and the state. The participants recognized explicitly, that in order to arrive at a meaningful desegregation plan, it had to clearly be undertaken in an arms length matter. We therefore separated those discussions from any discussion of an amount to compensate LDF and Joshua counsel for their time and expenses in litigating school desegregation issues 15 I ~ \ J I I I' ''I I l ' ,, I I , , I I I through the years until the conclusion of the settlement itself. 21. Paragraph IV.B. of the settlement was agreed upon before we reached a substantive discussion of the topic of fees and costs. It does not refer to those subjects. There was no discussion of fees and costs in the context of this provision. This paragraph deals in its entirety with "issues which have been raised, or could have been raised, in this Litigation . . . " as of the time of the settlement discussions. This did not include a fee request for the monitoring phase of the case, the parameters of which could not be known at the time of the settlement discussions. 22. Paragraph V of the agreement on the state's liability reflects the parties' settlement of the issue of attorneys' fees and costs for LDF and Joshua counsel. It is limited to compensation for the work through the preparation of the settlement. It does not by its terms address fees for the monitoring period. Moreover, in the context of discussions regarding this paragraph, no one took the position either that the fee settlement included compensation for the monitoring period, or that Joshua and/or LDF counsel were precluded from securing fees for any part of the monitoring period. I have read the foregoing statements and they are true and correct to the best of my knowledge and information. 16 ., -I I ) ,, , I' t fl I I J' \ i I I ,'t , , I SUBSCRIBED AND SWORN to before me this 2 / day of November, 1995. MY COMMI. SION EXPIRES: ''/ /1 "a'.' ~ NOTARY PUBLIC 17 I ,, I ! , , , , I I I t I l , , \ I I. t r -I I I John W. Walker, P.A. 1723 Broadway Little Rock, AR 72206 In reference to: Little Rock School District, et al. v. Pulaski County Special School District, et al.; Lorene Joshua, et. al.; Katherine Knight, et al. (lntervenors); NO. LR-C-82-866 DATE 02/18/90 02/26/90 03/12/90 03/12/90 03/21/90 06/28/90 ACTIVITY STATEMENT OF JOHN W. WALKER 1990 ACTIVITY HOURS Talked to Mayor Smith about Reville's letter .3 Attended two school suspension hearings .5 Tim Montgomery preparation, consultation, re: hearing for 03/13/90 1.0 Met with Arma Hart, re: Incentive Schools and dictated letter to her 3.5 Spoke with Pat Scarborough about Central High problem regarding Magnet School; spoke with Herts about one race result in student elections . 75 Talked to C. Heller re: loan approval motion; signed motion; reviewed settlement agreement prior to signing; talked to Wiley Branton about agreement .8 SUBTOTAL 6.85 Activity Statement John W. Walker 1 I I I I , , I I I t., l 1 \ I I I r \I I I DATE 01/03/91 01/04/91 01/05/91 01/06/91 01/08/91 01/09/91 01/10/91 01/11/91 01/13/91 01/14/91 01/15/91 01/16/91 01/17/91 01/18/91 ACTIVITY HOURS 1991 Began implementation discussions with counsel Discussions with counsel continued 2.5 3.1 Meeting with office staff re: ways to assist in implementing plan and helping districts identifying problem areas 3.0 Continued meetings re: office monitoring and implementation assistance 1.0 Plan for and meetings with district counsel re: desegregation implementation 6.2 Plan for and meetings with district counsel re: desegregation implementation 7 .1 Plan for and meetings with district counsel re: desegregation implementation 8.0 Plan for and meeting with sam Jones re: desegregation implementation 4.0 Received mandate from 8th Circuit .1 Discussions with counsel about plan changes; conference with Springer re: Joshua monitoring instrument 6.1 Conference with Heller regarding plan modifications, Incentive School - Aerospace School 5.3 Conference with Steele and Heller re: plan implementation; review of plan 4.4 Reviewed extended day provisions of plan; talked with Steele, Jennings, Heller 2.4 Read Order denying motions for reconsideration .1 Activity Statement - John W. Walker 2 I t I I' f, I I t t, 1 t \l I I I I t I, DATE 011/22/91 01/23/91 01/24/91 01/24/91 01/24/91 01/25/91 01/25/91 01/25/91 01/26/91 01/26/91 01/28/91 01/28/91 01/29/91 ACTIVITY HOURS Read part of Tri-District Plan; read part of LRSD Aerospace Magnet Plan; conference with Heller 3.5 Read 20 pages of Aerospace Magnet Proposal; conference with Heller and Steele 2.5 Prepare for Little Rock Hearing before Judge Wright on Aerospace Magnet School; conference with Heller and Paulson 3.2 Consideration of Magnet School Proposal; received fax from C. Heller regarding proposed stipulation; conferences with C. Heller; no agreement reached 1.2 Read letter to court from Burl lntervenors Prepared for Hearing before Judge Wright Preparation for and hearing before Judge Wright on Aerospace .2 1.1 Magnet School 3.0 Conference with Chris Heller about plan for the next day .3 Began review of QOM curriculum audit 1.2 Waited at Holiday Inn for Chris Heller who didn't show; read 40 pages of magnet application . 7 Met with Dr. Steele and Chris Heller about 2.0 gpa rule and Aerospace Magnet; telephone conferences with Heller and Jennings re: scholarship incentive 4.0 Called Dr. L.A. Davis to discuss his employment as expert, re: critique of Aerospace Magnet and to work with Angela Sewell to try to strengthen plan; Davis agreed to work for $45.00 per hour or $300.00 per seven hour day. He is to start at once; sent proposal to Pine Bluff by Vincent Maxwell; district is to reimburse costs; conferences with counsel 2.8 Obtained Little Rock Aerospace Project support - Mahlon Martin of Rockefeller Foundation; Dick Hulbert, Central Flying Service writings in support; conference with Heller; met with Activity Statement - John W. Walker 3 l ., , l ' , , I I \ :I, t I' II I I I f I I I DATE 01/30/91 01/30/91 01/30/91 01/31/91 02/01/91 02/02/91 02/03/91 02/04/91 02/04/91 02/04/91 02/07/91 ACTIVI1Y HOURS ministers re: plan Spoke with Chris Heller by phone, re: Aerospace Magnet; telephone conference with L.A. Davis, re: Aerospace Magnet and met with Committee and Dr. A. Sewell who agreed to work for $45.00 per hour or $300.00 per seven hour day. He is to 4.0 start at once; Sent proposal by Vincent Maxwell 4.5 Met with Dr. Davis, re: Little Rock proposals for Aerospace Magnet; began revising and drafting formal document 6.5 Order granting motion of Knight lntervenors for order to substitute class representatives .1 Continued to work on Aerospace Magnet issue; conferred with C. Heller, Dr. Steele, and parents, as well as expert Lawrence Davis; additional drafting and editing of proposal 11.5 Drafting, editing and redrafting plan for Aerospace Magnet for finalization for filing with Judge; conference with Heller, Springer, et al. 6.0 Four telephone conferences with C. Heller; telephone conference with Dick Hulbert, re: revising Aerospace Magnet School settlement; revising same with Mark B. 2.5 Preparation 2.1 Returned Chris Heller's call regarding settlement approval; conference with Hulbert, preparation 3.1 Worked with Chris Heller, Richard Roachell and J.S. on Aerospace proposal 2.0 Read Stipulation & Consent Order finding that the LRSD's desegregation plan is modified to include the Aerospace Technology Magnet School; spoke with C. Heller, and district officials .5 Conferences with counsel re: stipulation and extended day problems 1.5 Activity Statement - John W. Walker 4 I - I , . I 'I I I I I , , t \I '' I I, t l DATE 02/09/91 02/11/91 02/12/91 02/13/91 02/13/91 02/19/91 02/21/91 02/22/91 02/25/91 02/26/91 02/26/91 02/26/91 02/26/91 02/28/91 ACTIVITY HOURS Reviewed PCSSD's First Quarter Status Report for 1990-91 & Special Report concerning the J.C. Cook Elementary School .6 Reviewed Order granting motion of Burl lntervenors .1 Reaching agreement and entering Stipulation, filed by Joshua lntervenors, LRSD, PCSSD, NLRSD & Knight lntervenors, for approval of substituting Bonnie Brown in place of Sara Matthews Facen as class representative .4 Reviewed Order granting stipulation of parties re: class representatives .1 Read Stipulation & Consent Order concerning Washington and four other topics .6 Reviewed Affidavit of Richard N. Hulbert re: Aerospace Magnet School .2 Read letter to Stephen Jones re: concerns on memo with appearances of plagiarism and racism; attended school board meeting 2.2 Read State's letter to court re: funding payments from Dept. of Educ. to the Office of Desegregation Monitoring .2 Conference with Joshua monitoring team members to discuss monitoring LRSD schools 1.5 Review of letter from Sharon Street to Judge Wright .3 Received and reviewed letter to Chris Heller from Sam Jones; letter to Sam Jones .2 Review of letter from Sharon Street to Judge Wright .3 Received & reviewed letter to Chris Heller from Sam Jones; letter to Sam Jones .4 Read Order finding that the State is obligated under the terms of the settlement agreement to continue funding the ODM .1 Activity Statement - John W. Walker 5 1- 1 I I I ' II I I t i t I f '' f' I t 1 DATE 03/01/91 03/05/91 03/06/91 03/15/91 03/15/91 03/17/91 03/18/91 03/18/91 03/19/91 03/20/91 03/21/91 03/21/91 03/25/91 03/26/91 ACTIVITY HOURS Conference with Jennings, Matthis re: Incentive Schools 1.1 Meeting about plan m