Court Filings: District Court, affidavit of Opal Sims and affidavit of Ramsey Eddington

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. NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL. LORENE JOSHUA ET AL. KATHERINE KNIGHT, ET AL. STATE OF ARKANSAS COUNTY OF .~ O;rJ{)le.., AFFIDAVIT OF OPAL SIMS ) )ss. ) PLAINTIFFS DEFENDANTS INTERVENOR$ INTERVENORS Comes now the affiant, Opal Sims, who submits the following affidavit under oath: 1. I received a B.A Degree from the University of Arkansas at Pine Bluff in the Spring of 1980. My program involved a major in the area of physical education and a minor in science. 2. I worked as a substitute teacher in the Plum Bayou Tucker School District during the 1980-81 school year. In 1982 and 1983, I worked in the Job Corps center located in Little Rock. During a part of this employment, I taught a "life skills" course to persons served by the center. In 1984 and 1985, I worked as a program manager for Arkansas Career Resources, a non-profit agency located in Little Rock. My work involved developing programs to promote the movement of women from welfare status I I I I I I I I I I I I I I I I I I I to involvement in the work force. 3. I was employed as a "state program specialist" by the Action Agency, an agency of the United States Government, from February 1986 until 1990. The Action Agency provides funds to generate volunteer activities and takes measures to promote use of the monies in an effective manner, consistent with federal regulations. My work included management oversight, program development, training, program evaluation, and monitoring of programs. My monitoring activities involved on-site review of 25 to 30 programs a year and included observation of the programs, review of records, interviews, and preparation of written reports to the regional office of the Action Agency. 4. I was employed by the John W. Walker law firm in the period from April 8, 1991 through July 7, 1991, as one of the members of the team which prepared the first Joshua Monitoring Report. My work included the following tasks: helping to develop the monitoring instrument; visiting schools; interviewing principals, teachers, and support staff; observing classes; compiling data; writing reports on findings at particular schools; conferring with other monitoring team members and John W. Walker; and helping to write the overall monitoring report, including the recommendations. 5. During my work at the Walker firm, I prepared daily records reflecting the time which I worked and the nature of my activities. Attachment One to this Affidavit sets forth my time and activities, based upon those records. I have read the foregoing affidavit and it is true and correct to the best of my knowledge and information. I I I I I I I I I I I I I I I I I I I OPAL SI SUBSCRIBED AND SWORN to before me this ,2,/ day of /(J{),1,&41{) /J$/ , 1995. MY COMMISSION EXPIRES: 9/ n f:ul!::, YPUBLIC I I I I I I I I I I I I I I I I I I I ACTMTY STATEMENT - OPAL SIMS 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) DATE 04/08/91 04/09/91 04/09/91 04/10/91 04/10/91 04/11/91 04/11/91 04/12/91 04/12//91 04/15/91 1991 ACTMTY HOURS Reviewed monitoring instruments; reviewed PCSSD proposed desegregation plan 6.6 Reviewed PCSSD's proposed desegregation plan 3.0 Visit to lsh Incentive School to monitor classes and conference with school principal 4.0 Reviewed interdistrid desegregation plan 3.0 Visit to Garland Incentive School to monitor classes; visit with teachers and held conference with principal 4.0 Reviewed NLRSD's desegregation plan 3.0 Visit to Stephens Incentive school to monitor classes; visit teachers and instrudional aides; and held conference with principal 4.6 Visit with Dr. Cheryl Simmons to discuss increasing parent involvement in school and to schedule parent meeting for an evening at the school .6 Meeting with Joshua monitoring group to review visits for week and to plan reporting 2. 7 Worked on locating phone numbers, addresses of parents with children attending Garland Incentive School; worked on letter notifying parents of meeting scheduled for 4/18 3.0 1 I I DATE ACTIVITY HOURS I 04/15/91 Picked up mailing list of Garland Incentive School parents from LRSD Administrative offices .3 I 04/15/91 Worked on mailing notices for Thursday night meeting at Garland Incentive School 6.0 I 04/16/91 Brady Elementary School observation of classrooms and conference with principal 3.0 I 04/16/91 Went to Bale Elementary School to drop off survey to Mrs. Wilson .5 I 04/16/91 Visited Fuller Jr. High and Mills High School for principal's conferences and classroom observations 4.0 I 04/17/91 Compiled notes from monitoring visits made to Garland, I Stephens, and Bale Elementary Schools 3.0 04/18/91 Attended meeting between attorneys for the PCSSD, LRSD and I Joshua to discuss desegregation plan 2.0 04/18/91 Observation of classroom and conference with principal at I Romine Elementary School 3.0 04/19/91 Conference with monitoring team Mrs. Charles and Mrs. Rouse I to review visits made during the period 4/15-4/18 and to plan for week of 4/22-4/26 1.5 I 04/19/91 Made phone calls to elementary schools to schedule visits for week beginning 4/22 and prepared folders on each school 5.0 I 04122/91 Visit to Fairpark Elementary School for principal confrerence and classroom observation 3.0 I 04/22/91 Visit to Badgette Elementary school for principal conference and classroom observation 2.0 I 04/23/91 Visit to Mabelvale Elementary School for principal conference and classroom observation 2.0 I 04/23/91 Visit to Chicot Elementary School for principal conference and I 2 I I I DATE ACTIVITY HOURS I classroom observation 2.0 I 04/24/91 Visits made to Baseline & Meadowcliff Elementary Schools for principal conferences and classroom observation 5.5 I 04/25/91 Visits made to Fulbright, Williams and Jefferson Elementary Schools for principal conferences and classroom observation 6.0 I 04/29/91 Visted Wakefield, Geyer Springs and Western Hills Elementary Schools for principal conferences and classroom observation 5.0 I 04/29/91 Made phone calls to parents of Garland Incentive School students to remind them of 4/30 meeting 2.0 I 04/30/91 Visits to Cloverdale, and Watson Elementary Schools for principal conferences and classroom observation 4.0 I 04/30/91 Phone calls to parents about meeting scheduled for 7:30 at Garland Incentive School 1.0 I 04/30/91 Went to Bale Elementary School to pick up survey form. It was not completed as planned (the secretary will call when the form I is completed) .5 04/30/91 Meeting with parents of students attending Garland Incentive I School 2.5 05/01/91 Visits to Gibbs Magnet School and Dunbar Jr. High for I conferences with the principals and classroom observation 4.0 05/02/91 Visit to Mam Magnet and Central High Schools for conference I with principals and classroom observation 4.0 I 05/03/91 Made phone calls to schools in LRSD to schedule appointments for week of 5/6-10 and worked on narratives/survey forms from schools visited during the week 7.0 I 05/06/91 Picked up survey forms from the following schools: Mabelvale Elementary, Wakekfield Elementary, Wilson Elementary, I Western Hills Elementary, Geyer Springs Elementary, Meadowcliff Elementary, Baseline Elementary 5.0 I 3 I I I DATE ACTIVITY HOURS I I 05/06/91 Phone calls to parents to remind them of Tuesday night meeting at Garland Elementary School 2.0 I 05/07/91 Visits to Dunbar Jr. High and Woodruff Elementary for principal conferences 4.0 I 05/09/91 Visits to Metropolitan Vo-Tech and Southwest Jr. High for visit with principals and classroom observation 6.0 I 05/10/91 Organized files and completed survey forms on schools visited to date 4.0 I 05/10/91 Conference with Joshua monitoring team members to plan for I final report and scheduling of visits 2.0 05/13/91 Visited Forest Heights, Jr. High and Mabelvale Jr. High for I conference with the principals and classroom observation 6.0 05/14/91 Visited JA Fair and Washignton Elementary for conference I with the principals and classroom observation 4.0 05/15/91 Visited Scott Elementary and North Little Rock High School for I conference with the principals and classroom observation 5.0 05/17/91 Picked up survey forms from Watson Elementary, Cloverdale I Elementary and Hendeson Jr. High; visited classroom at Henderson Jr. High 2.5 I 05/20/91 Visited Oak Grove Elementary Jr. High and Sr. High for conferences with principals and classroom observation 6.0 I 05/21/91 Visited Robinson Elementary, Robinson Jr. High and Robinson Sr. High for principal's conferences and classroom observation 6.0 I 05122/91 Visits made to Sylvan Hills Elementary, Sylvan Hills Jr. High and Sylvan Hills High School for principal's confrences and I classroom observation 6.0 05/23/91 Visits to Agenta Elementary, and Ridgeroad Middle School for I principal's conferences and classroom observation 4.0 I 4 I I I DATE ACTMTY HOURS I 05/28/91 Visited Metropolitan Vocational-Technical Center for conference with the principal and classroom observation 2.0 I 05/29/91 Made phone calls to schools to schedule appointments to secure survey forms; worked on compiling monitoring materials 6.0 I 05/30/91 Visited LRSD Alternative School Leaming Center for a conference with the principal; also visited Central High School I for classroom observation and teacher conferences 5.5 05/31/91 Visited Scott Elemetary school to pick up survey data; visited I some classrooms. Conference with team members to discuss progress to date 4.0 I 06/03/91 Compiled monitoring materials for report 3.0 I 06/03/91 Franklin Elementary school; helped to conduct interview for Incentive school teachers for the 1991-92 school term 2.0 I 06/04/91 Meeting with Ann Brown, Desegregation Monitor, to discuss monitoring activities in the tri-district schools 2.5 I 06/05/91 Conducted interviews for Incentive School teachers at Franklin Elementary for 1991-92 school year 2.5 I 06/06/91 Picked up survey forms from Fuller Jr. High and MIiis High School 1.0 I 06/07/91 Worked on monitoring report 4.0 06/10/91 Compiled Incentive School data for monitoring report 4.0 I 06/10/91 Participated in interviews for prospective teachers for Franklin I Incentive School for 1991-92 school term 2.5 06/11/91 Worked on LRSD monitoring report 4.0 I 06/12/91 Worked on LRSD monitoring report 6.0 I 06/12/91 Participated in interviews for Franklin Incentive School teaching staff for 1991-92 school year 2.0 I 5 I I I DATE ACTMTY HOURS I 6/13/91 Worked on LRSD monitoring report 7.5 I 06/14/91 Worked on LRSD monitoring report 4.0 06/14/91 Participated in interviews for Franklin Elementary Incentive school I teachers for the 1991-92 school year 3.0 06/17/91 Worked on LRSD monitoring report 7.0 I 06/18/91 Worked on LRSD monitoring report 7.0 I 06/19/91 Worked on monitoring report for LRSD 8.0 I 06/19/91 Conference with Karen Buchanan, principal at Washington Magnet School 2.0 I 06/20/91 Worked on monitoring report for LRSD 6.0 06/21/91 Worked on monitoring report for the LRSD 8.0 I 06/22/91 Participated in interviews for Franklin Incentive School teachers for the 1991-92 school year 3.0 I 06/24/91 Worked on monitoring report for LRSD 6.0 I 06/25/91 Writing of monitoring report section on the LRSD 8.0 06/26/91 Writing monitoring report on LRSD 6.0 I 06/27/91 Writing monitoring report for LRSD 6.0 I 06/28/91 Meeting with teachers from Cloverdale Jr. High School to discuss concerns about the school's administration 3.5 I 06/28/91 Wrote up concerns voiced by Cloverdale Jr. High teachers to be included in the LRSD monitoring report 4.0 I 07/01/91 Worked on monitoring report for PCSSD 7.5 I 07/02/91 Worked on PCSSD monitoring report 6.0 I 6 I - -- -- - - - - - - I I I I I I I I I I I I I I I I I I I DATE 07/03/91 07/03/91 07/05/91 07/06/91 07/08/91 07/09/91 07/09/91 ACTIVITY HOURS Worked on PCSSD monitoring report 4.0 Worked on NLR School District monitoring report 3.0 Compiled numerical data from LRSD, survey forms (incentive, area, magnet elementary schools; magnet and area Jr. High & magnet and area Sr. High schools) 7.5 Compiled numerical dta from LRSD survey forms (nicentive, area, magnet elementary schools; magnet and area Jr. High schools and magnet and Area High schools) 7.0 Using numerical data from survey froms and talley sheets made revisions to LRSD monitoring report. Also made additional editing/proofing changes 8.0 Worked on revisions to LRSD monitoring report 3.0 Worked on recommendations to be presented to LRSD administrators re: findings/concems from the monitoring report 3.5 TOTAL HOURS EXPENDED 365.3 7 I I I I I I I I I I I 1 I I I I I I I IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCKSCHOOL DISTRICT, ET AL. V. NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT, ET AL. LORENE JOSHUA ET AL. KATHERINE KNIGHT, ET AL. STATE OF ARKANSAS COUNTY OF l cnc,KL AFFIDAVIT OF RAMSEY EDDINGTON ) )ss. ) PLAINTIFFS DEFENDANTS INTERVENOR$ INTERVENOR$ Comes now the affiant, Ramsey Eddington, who submits the following affidavit under oath: 1. I am a Certified Public Accountant with my own business located at 201 S. Chester, Little Rock, Arkansas. I compile the business records of John W. Walker, P.A. 2. From data previously secured from the Walker law firm, I compiled the amounts paid by the Walker law firm to Clemetine Rouse, Evelyn Jackson, Delores Sykes, Kirke Herman, Debbie Parker, and LaRhonda Pondexte for the calendar years 1991, 1992, 1993, and 1994. This information is as follows: I I I ., I I I I I I I I I I I I I I I PAYEE 1991 1992 1993 1994 Clementine Rouse 2200.00 1000.00 2000.00 Evelyn Jackson 2700.00 Delores Sykes 1000.00 3600.00 3600.00 Kirke Herman 16675.00 8400.00 12732.00 4587.00 Debbie Parker 26,225.81 LaRhonda Pondexter 5218.74 6875.00 I have read the foregoing affidavit and it is true and correct to the best of my knowledge and information. I f.a lr RAMSEt}DDI roN SUBSCRIBED AND SWORN to before me this / 7 day of _ _.;.A._' --,-~L';..._;v__. _ _, 1995. MY COMMISSION EXPIRES: 4/ 1'7 / 200 3 / I NOTARY PUBLIC I I I I, I I I' I I I I I I I I II I I I CERTIFICATE OF SERVICE I, John W. Walker, hereby certify that a copy of the foregoing Motion and Memorandum of the Joshua lntervenors for an Interim Award of Attorneys' Fees and Costs for Post-Judgment Monitoring have been served individuals listed below, by placing a copy of the same in the United States Mail with sufficient postage prepaid, on this 21st day of November, 1995. Steve Jones, Esq. Jack, Lyon & Jones, P.A. 3400 Capitol Towers Capitol & Broadway Streets Little Rock, AR 72201 Christopher Heller, Esq. Friday, Eldredge & Clark . 2000 First Commercial Building Little Rock, AR 72201 Jerry Malone, Esq. rJo Little Rock School District 81 O West Markham Little Rock, AR 72201 Sam Jones, Esq. Wright, Lindsey & Jennings 2200 Worthen Bank Building Little Rock, AR 72201 Richard Roachell, Esq. Roachell & Streett 401 W. Capitol Ave. Suite 504 Little Rock, AR Ms. Ann Brown, Monitor Office of Desegregation Monitoring 201 East Markham, Suite 510 Little Rock, AR 72201 Tim Humphries, Esq. Attorney General's Office 200 Tower Building 323 Center Street Little Rock, Ar 72201 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.