District Court, motion for extension of time; District Court, Knight, et al.,'s reply to Pulaski County Special School District (PCSSD) response to motion; District Court, notice of appeal; District Court, Pulaski districts' motion for summary judgment on the issues of health insurance, special education, and loss funding; District Court, statement of material and undisputed facts with respect to the Little Rock School District (LRSD), Pulaski County Special School District (PCSSD), and North Little Rock School District (NLRSD) motion for summary judgment on the issues of health insurance, special education, and loss funding; District Court, motion for hearing; District Court, order; District Court, supplement to Pulaski County Special School District (PCSSD) motion to enlarge Jacksonville North and South (junior high schools); District Court, Pulaski County Special School District (PCSSD) motion to fix time; District Court, three orders; District Court, motion for extension of time in which to file notice of appeal; District Court, judgment; District Court, order; District Court, notice of filing, Arkansas Department of Education (ADE) semiannual monitoring report; District Court, notice of filing, Arkansas Department of Education (ADE) project management tool; District Court, notice of filing, Little Rock School District (LRSD) program planning and budgeting tool The transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors. u.s~,\k~JdRr EASTERN OISiRICT ARK,\NSAS IN THE UNITED STATES DISTRICT COURT JAN 6 1997 EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT V. NO. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL. MRS. LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. JAMES W McCORMACK, CLERK By: -----------PLRiN'PfFf1( DEFENDANTS INTERVENORS INTERVENORS MOTION FOR EXTENSION OF TIME Knight, et al., Intervenors, by and through their attorneys, ROACHELL L-\ W FIR:.\1. for their Motion, state: 1. PACT, by and through Knight, et al. Intervenors, filed a Motion for Extension of Time until close of business on Monday, January 6, 1997, to file its Reply to the Response of PCSSD. 2. The data collection for the reply by PACT personnel was severely curtailed during the holidays as they only returned to work on the morning of January 6, 1997. The data collected by PACT did not arrive at its attorneys office untii the afternoon of January 6, i 997 and a proper reply is not possible prior to close of business. WHEREFORE, PACT prays that it be granted one additional day to file its Reply to the Response of PCS SD and be granted all other relief to which it may be entitled. Respectfully submitted. c==>____,, ~ Richard W. Roache!! Arkansas Bar No. 78132 ROACHELL LAW FIR2v1 401 West Capitol Avenue, Suite 504 The Lyon Building Little Rock, Arkansas 72201 (501) 375-5550 CERTIFICATE OF SERVICE I, Richard W. Roachell, do hereby certify and state that a true and correct copy of the foregoing was mailed, postage prepaid, on January 6, 1997 to the follo,,ing persons: Mr. John W. Walker John W. Walker, P.A. 1 723 Broadway Little Rock, AR 72201 Ms. Ann Brown ODM Heritage West Building, Ste. 510 201 East Markham Street Little Rock, AR 72201 Mr. Timothy Gauger Assistant Attorney General 323 Center Street, Suite 200 Little Rock, AR 72201 2 Mr. Christopher Heller FRIDAY, ELDREDGE & CLARK 2000 First Commercial Building Little Rock, AR 72201 M. Samuel Jones III WRIGHT, LC\l)SEY & JEi'IN"L\,.GS 200 West Capitol Avenue Little Rock, AR 72201 Mr. Stephen W. Jones 3400 TCBY Tower 425 West Capitol Avenue Little Rock, AR 72201 ~ ~ Richard W. Roachell FILED u S DISTRICT COURT EASTERN DISTRICT ARKA SAS IN THE UNITED STATES DISTRICT COURT JAN 7 1997 EASTERN DISTRICT OF ARKA SAS ERK WESTERN DIVISIO JAMES W McCORMACK, CL l By: -----nioE:i:p,7_C' IL8ER=iip1"0xlmately $800,000. The cost tor lnitlal materiats and equipment for the MUls High School Specialty Program It $300,000. Tht Olst,1e:t wu required to shift elementary assimnt prtncipais from tl'le Chapter I budget to tl'lt OISU'id OJ)eraUng budQet at a cost of $250,000. The cost for lmptememtno the Economic Education Specialty Program it Baker Elementary school ls $60,000. A new board policy requil'ln9 drug lt~ng of bus drivers ccsts $20,000. The total of these new expenses for 1993-94 ls $2,9~.220. In spite of the ract tl'lat focal revenue Increased by ~.305,S55. prfma,uy as a result of the new 6 mill tax. the Joss ot $959,846 in state and federal revenue caused the Olstnct to have only $1.1S9.121 in new available revenue over the expenses of 199293. These racu place the District In the position .t profectlnQ a ($1,789.099) deflol for the 1993-~ school year. PROBLEM 0EFfNITION To develop a balanced budget th, PCSSO -'dminlstratlon and Board had to txplore varlc,us ways lo rtduce expenditures. AU areas of budgeted excenses had to be examined u i,otent1al blJdQet arts In an effort to reduce expenditures by approximately S2,000.000 tor the 1993.94 school year. Slgniffcant ntdUctlons were made in oper;tlcns costs ($510.000} and In debt cests ($200,000). The decision was ffnaHy rNde to delete mree student interadlon days In order to save approximately S1 .soo.900. ANALYSIS OF ALTERNATIVES The altematlves that were considered were: (1) ReductlOn ot salaries of all personnel (2) Elimination of programs not required by edUcatlon standards or !ht desegregatiOn plan (3) Reouction in lorce ot personnel not required by education $tandards or the dese9regatlon plan. To reduce salaries of all personnel would viol.le At1(a~ Slate Law 6-17-1501 "'The Teacher Fu - Dismissal Act of 1963." Subchapter 6-17-1506 provides that "(a) Every contract ot emptoyment made ti 1311 betwon a teacttet and the board of directors of a scl'lool district shall be renewed in wrttl~ on the same terms and for the same salary, unless Increased or decreased by law. for the nex1 school year succeeding the date ot termination tlxed therein. which renewal may be made by an endo~ement on the existing contract lnS11t1ment. unless by May 1 of the contract year. the teacher is notified by the school superintenderlt that the superlntendenl Is recommendlnc;, that the teacher's contract not be renewed: Since the May t deadline had passed, ~ was determined that vfolatlon of this statute could lead to lengthy nugatlon and much expense in legal fees. The penalty tor Ignoring this law was an "Unknown. Furthermore. employees would resent woc1wT, penalty. Forces against this approach are employees whO do r.ct want their salartes to be neQatfvely affected and parents who are concerned that their children will suffer educatlonally. IMPLEMENTATION FLAN The PCSSO Board of Educs1lon adopted the 1993-94 budget which provided for deletion of three student Interaction days at a special school board mcetl~ on July 27, 1993. Thls action Is contingent on Court approval. The proposal has already received considerable media attention without any appreciable opposition from patrons. However, students. employees. and parents will be nofl11ed of the possibility of the deletion of the fast three days of the school year so that summer plans can be considered. Should it be unnecessary to delete all three days. constituents will be notified at the eartlest time possible. Every effort will be made lo curtail expenditures durt~ the schOol year in an effort to prevent deletion of any school days. Furthermore, a strategic plan has been Implemented to encourage patrons lo approve the restructuring of the Dfstnct's Indebtedness. The District is considering ways to atfect employee salaries by withholdln9 pay in incremems rather than withholdtng for all three days during the fast pay period. SUMMARY OF "BUDGET AMOUNTS" 19')6 - 19'J7 PCSSD FINANCIAL REPORTS FUND 1000 TEACHER SALARY FUl\.ro 1100 11115 Ill( Jl}f_l 113<) 114' ! 150 IIC,O 1170 1191 121n 12! I 12:!I! !240 12(,(l 1:10 l2S5 1121) l~_~I !.""'1) U5o u~_; ])C,(l 1370 1390 13~.1 15' , 19JfJ 1930 2111 2122 1142 21.:;o ::211 1212 2222 :!321 :!411) :!4~ 2501 ::(;JO 27!0 2i:,, 2PO C.\(,1 DE3CR!PTION Rc-g P@Jw'Elcm-SccooJa,y Pre-School Ku~ortro Elrnicntary Middle ' Jr 1-hgh lhgh School AthletJcs Stu.Jient Aci.J\ilic:. Sununc, School ROTC llincrMt lnstrucuon HClUlCOO).),.J 13(l -1::.&-'6 (l() 14S.SIOOO iSI.4::? 00 IJ~. 77 I IY! ~..a9o,;-:. \)0 ~32.1 :4 (>.,_, J11~,.,,n1_(1 -Y..14."~'{') J.,.<_~!-4.00 ~:S.i II 00 lS.ti5$ l lt--.~_--:,c.; ,,fl l-'.':' ~~71111 ..,J -~ ,, ._1 7" 7, "l,lf !(I :,~s.7r:.-: ((1 :G9.53S 00 ~--: 7:7('1 ,. ,l~- l i{H)'I 1.12 11:2 , .J ~A J_'7-l22h(I :_!.;r_:.,ll'O 211.81800 77i l(;Sr,J l ,i.W ... ll1.a) -:.u,, c,~, , 11:1 1,4_.., ,.77 1(1 !<1~ __ 111 2.n,,:.~: 1)1) :!_!)').;_::?.(>') s:.c1 7 oo l~:.87<. 00 ,.., 1,j-! ().j '.'k ..:;:_J ((i j~(J ,..t..t ( (t .1~ .......... 1(1 0 47.()()()()() 2. 7-1~_985 (~) 12.952.~'>t-l( 5,8'56,!:>43 (