Court filings: District Court, motion for approval of Little Rock School District's (LRSD's) revised desegregation and education plan

This transcript was created using Optical Character Recognition (OCR) and may contain some errors. IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DMSION LITILE ROCK SCHOOL DISTRICT V. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL MRS. LORENE JOSHUA, ET AL KATHERINE KNIGHT, ET AL OFFiCE OF DESEGREGATiOiu t,10.'JITORINJ MOTION FOR APPROVAL OF PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS LRSD'S REVISED DESEGREGATION AND EDUCATION PLAN For its motion, the Little Rock School District (LRSD") states: 1. This court has expressed the view that modifications of LRSD' s Desegregation Plan might be appropriate. The court has properly recognized that the parties themselves must develop and present any proposed modifications, but has provided expert testimony concerning potential areas for modification. The court further assisted the plan modification process by providing LRSD a period of time during which the district could concentrate its efforts on developing plan modifications to improve education and desegregation within the district. Order, December 27, 1996. LRSD has prepared a modified plan for the purpose of providing improved education and desegregation. LRSD' s Revised Desegregation and :Education Plan is attached as Exhibit A to this motion. 2. LRSD's Revised Desegregation and Education Plan was developed in accordance with the plan amendment process. All of the parties to this case received early drafts of the plan and had the opportunity to make suggestions concerning the plan. LRSD amended the plan in response to suggestions made by various parties. In addition, the Joshua Intervenors were specifically asked whether they bad any ideas for improving the LRSD Desegregation Plan. Joshua did not make any suggestions for plan modifications. Although much of the contact soliciting responses from other parties was made by telephone, the correspondence which reflects the distribution of LRSD' s Revised Desegregation and Education Plan and our solicitation of responses from the other parties is attached as Exhibit B to this motion. 3. On September 18, 1997 the LRSD Board of Directors voted unanimously to adopt the Revised Desegregation and Education Plan and to present it to the district court for approval. The comments of the board members, attached as Exhibit C, show that they gave serious consideration to the plan and that they understand the important commitment they have made to work for the success of the plan if it is approved by the district court. Representatives of the Little Rock Chamber of Commerce and the Little Rock Alliance for Our Public Schools expressed to the board their strong support for the Revised Desegregation and Education Plan. 4. The United States Supreme Court has emphasized in the recent cases of Freeman v. Pitts and Missouri y. Jenkins that the district court's end purpose in a desegregation case is not only to remedy the violation to the extent practicable, but also to restore state and local authorities to control of a school system that is operating in compliance with the Constitution. The Revised Desegregation and Education Plan provides a means by which this court can 2 accomplish both the maximum practicable desegregation within LRSD and the restoration of local control to the LRSD Board of Directors and the citizens of Little Rock. 5. LRSD's current desegregation plan was designed to operate for a period of six years. It is too detailed, too complex and too rigid to provide LRSD the greatest possibility for long term desegregation. The primary architects of the old plan are no longer with the district. The Revised Desegregation and Education Plan retains the core desegregation commitments found in the old plan, but is premised on the belief that a solid education program provides the best foundation for long term desegregation. 6. The new plan also provides the flexibility necessary for LRSD to adapt to changing educational and demographic conditions. LRSD has more freedom under the new plan to adjust the means by which it seeks to reach its desegregation and education goals without unnecessary court involvemenL Under the present plan, every detail concerning implementation of the plan is a part of the plan itself and cannot be changed without involving the court. 7. This court previously found that LRSD would benefit from a temporary hiatus from monitoring in order to develop proposed modifications to the LRSD Desegregation Plan. Order, December 27, 1996. LRSD asks the court to continue the temporary hiatus from monitoring during the court's consideration of the Revised Desegregation and Education Plan. 8. As part of the effort to allow the parties to focus on the development of modifications to the LRSD Desegregation Plan, LRSD withdrew its motion for reconsideration of this court's ruling on LRSD's Motion to End Federal Court Jurisdiction. The court granted LRSD a period of time to and including September 30, 1997 within which to refile its motion 3 for reconsideration. LRSD asks that that deadline be extended until a reasonable time following this court's final determination with respect to the Revised Desegregation and Education Plan. 9. This Motion For Approval of LRSD's Revised Desegregation And Education Plan should not be construed as a waiver of the positions expressed in the Motion to E.nd Federal Court Jurisdiction. 10. LRSD's memorandum brief in support of this motion is hereby incorporated by reference. WHEREFORE, for the reasons set forth above and in the accompanying brief, LRSD moves for an order approving its Revised Desegregation and Education Plan and, during the pendency of this motion, extending this court's December 27, 1997 Order with respect to monitoring and with respect to LRSD's right to refile its motion to reconsider the court's ruling on LRSD's Motion to End Federal Court Jurisdiction. Respectfully submitted, LITTLE ROCK SCHOOL DISTRICT Christopher Heller John C. Fendley, Ir. FRIDAY, ELDREDGE & CLARK 2000 First Commercial Bldg. 400 West Capitol Street Little Rock, AR 72201 (501) 376-2011 By:~(?_-~~ ~C. Fendley, Jr. ' Bar No. 92182 4 CERTIFICATE OF SERVICE I certify that a copy of the foregoing Motion For Approval of LRSD's Revised Desegregation and Education Plan has been served on the following by depositing copy of same in the United States mail on this 26th day of September, 1997. Mr. John Walker JOHN WALKER, P.A. 1723 Broadway Little Rock, AR 72206 Mr. Sam Jones WRIGHT, LINDSEY & JENNINGS 2200 Worthen Bank Bldg. 200 West Capitol Little Rock, AR 72201 Mr. Steve Jones JACK, LYON & JONES, P.A. 3400 TCBY Tower 425 Capitol A venue Little Rock, AR 72201 Mr. Richard Roachell Roachell Law Firm 401 West Capitol, Suite 504 Little Rock, AR 72201 Mr. Timothy G. Gauger Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, AR 72201 Ms. Ann Brown - HAND DELIVERED Desegregation Monitor Heritage West Bldg., Suite 510 201 East Markham Street Little Rock, AR 72201 ~e.~fJ C.F~ 5 I. Little Rock School District Revised Desegregation and Education Plan September 18, 1997 Prior A~reements and Orders. This Revised Desegregation and Education Plan shall supersede and extinguish all prior agreements and orders in Lillie Rock School District v. Pulaski County Special School District, U.S.D.C. No. LR-C-82-866, and all consolidated cases related to the desegregation of the Little Rock School District ("LRSD") with the following exceptions: A. The Pulaski County School Desegregation Case Settlement Agreement as revised on September 28, 1989 ("Settlement Agreement"); B. The Magnet School Stipulation dated February 27, 1987; C. Order dated September 3, 1986, pertaining to the Magnet Review Committee; D. The M-to-M Stipulation dated August 26, 1986; and, E. Orders of the district court and court of appeals interpreting or enforcing paragraphs A. through D. above to the extent not inconsistent with this Revised Desegregation and Education Plan. II. Obligations. A. LRSD shall use its expertise and resources to comply with the Constitution and provide an equal educational opportunity for all students attending LRSD schools and to ensu_re that no person is discriminated against on the basis of race, color or ethnicity in the operation of LRSD; B. LRSD shall implement programs, policies and/or procedures, including but not limited to recruitment practices and reasonable measures to maintain a pool of qualified AfricanAmerican applicants, designed to ensure that LRSD hires qualified African-Americans in EXHIBIT A proportion to their percentage in the relevant labor market; C. LRSD shall implement programs, policies and/or procedures, including but not limited to reasonable measures to maintain a pool of qualified African-American candidates, designed to ensure that LRSD promotes qualified African-Americans in proportion to their percentage of the pool of candidates eligible for promotion; D. LRSD shall implement programs, policies and/or procedures designed to ensure that to the extent practicable the percentage of African-American certified personnel in each LRSD school is within plus or minus fifteen percentage points from the percentage of AfricanAmerican certified personnel in the district as a whole; E. LRSD shall implement programs, policies and/or procedures designed to ensure to the extent practicable that the certified personnel at one race, African-American schools (2. 90% African-American) is comparable with the certified personnel at other LRSD schools with regard to years of teaching experience and number of teachers with advanced degrees; F. LRSD shall implement student assignment programs, policies and/or procedures designed to ensure the desegregation of LRSD schools to the extent practicable; G. LRSD shall implement programs, policies and/or procedures designed to ensure that there is no racial discrimination in the referral and placement of students in special education; H. LRSD shall implement programs, policies and/or procedures designed to ensure that there is no racial discrimination with regard to student discipline; I. LRSD shall implement programs, policies and/or procedures designed to promote participation and to ensure that there are no barriers to participation by qualified African- 2 Americans in extracurricular activities, advanced placement courses and the gifted and talented program; J. LRSD shall implement programs, policies and/or procedures designed to improve the academic achievement of African-American students, including but not limited to Section V. of this Revised Desegregation and Education Plan; K. LRSD shall implement programs, policies and/or procedures designed to promote and encourage parental and community involvement and support in the operation of LRSD and the education of LRSD students; L. LRSD shall implement programs, policies and/or procedures designed to ensure an equitable allocation of financial, technological and educational resources to LRSD schools; M. LRSD shall implement programs, policies and/or procedures designed to ensure equitable maintenance and repair of LRSD facilities; N. LRSD shall implement programs, policies and/or procedures designed to ensure that there is no racial discrimination in the provision of guidance and counseling services; 0. LRSD shall implement programs, policies and/or procedures designed to ensure that every LRSD school provides its students a learning environment free from discrimination; and, P. LRSD shall implement programs, policies and/or procedures designed to ensure LRSD substantially complies with its obligations under this Revised Desegregation and Education Plan. III. Student Assignments. A. Attendance Zones. Before the 1998-99 school year, LRSD attendance zones shall 3 be redrawn in accordance with the following guidelines: 1. Neighborhood Schools. LRSD shall assign students to area1 elementary and junior high/middle schools based on reasonably compact and contiguous attendance zones drawn to create as many truly desegregated schools (from forty to sixty percent AfricanAmerican) as reasonably practicable, except as provided in subparagraph 2. below; 2. Exception. Where a reasonably compact and contiguous attendance zone will result in an elementary or junior high/middle school which is less than twenty percent African-American, LRSD reserves the right to either: a. Draw the attendance zone at less than full capacity to allow for the voluntary transfer of African-American students to the school; or, b. Create one or more satellite attendance zones of primarily African- American students. 3. High Schools. LRSD shall assign students to area high schools based on attendance zones drawn so that the percentage of African-American students at each high school shall be within plus or minus twenty percentage points from the percentage of African-American students for high schools as a whole and so that, to the extent practicable, a stable and predictable feeder pattern exists from LRSD junior high/middle schools. B. Voluntar:y Student Transfers. Beginning in the 1998-99 school year, the following guidelines shall govern voluntary student transfers: 1. Desegregation Transfers. LRSD students whose race constitutes more than 1The term "area" school shall refer to all LRSD schools except magnet and interdistrict schools. 4 sixty percent of the population at their attendance zone school shall be permitted to transfer to another LRSD area school where their race constitutes less than forty percent of the student population subject to capacity limitations and to reasonable requirements established by LRSD; 2. Racial Isolation Transfer. LRSD students whose attendance zone school is a one race, African-American school (2.. 90% African-American) shall be permitted to transfer to another LRSD area school subject to capacity limitations and to reasonable requirements established by LRSD; 3. Magnet Program Transfer. LRSD students shall be permitted to transfer to another LRSD area school to participate in a designated magnet program subject to capacity limitations and to reasonable requirements established by LRSD; 4. Employees' Child Transfer. LRSD employees who reside in the LRSD may choose to have their children attend the same school or campus at which the employee works, not including Magnet schools, subject to capacity limitations and to reasonable requirements established by LRSD; 5. Special Circumstances Transfer. Upon a showing of a special need arising out of circumstances unique to a particular student, a student may, at the sole discretion of LRSD, be permitted to transfer to another LRSD area school subject to capacity limitations and to reasonable requirements established by LRSD; 6. Outside Students. LRSD schools shall be open to students who reside outside Pulaski County where the acceptance of the transfer will improve the racial balance of the district as a whole and of the school to which the student wishes to transfer and subject to capacity limitations and to reasonable requirements established by LRSD; and, 5 7. Transportation. LRSD shall provide transportation to voluntary transfer students with the following exceptions: (i) employee's child transfers, (ii) special circumstances transfers, and (iii) transfers from outside Pulaski County. C. Magnet Programs. The designated magnet programs at this time are the following: 1. Rockefeller Early Childhood Program; 2. King High Intensity Learning Program; 3. Washington Math Science Program; 4. Henderson Health Science Program; 5. Dunbar International Studies/Gifted and Talented Program; 6. Central International Studies Program; and, 7. McClellan Business Communications Program. LRSD reserves the right to modify or discontinue designated magnet programs and to establish new magnet programs. D. Middle Schools. LRSD shall establish a schedule for the orderly conversion of some or all of its junior high schools to middle schools for grades six, seven and eight and move the ninth grade to high schools. As a part of this conversion, LRSD reserves the right to change the grade level structure at all of its schools, including magnet schools. E. School Construction/Closing. LRSD shall construct two new area elementary schools, one in west Little Rock and one at the site of the former Stephens school. When the new Stephens Elementary opens, Garland Elementary School shall be closed. F. Modification Standard; During the term of this Revised Desegregation and 6 Education Plan, LRSD shall not recommend additional modifications to attendance zones or grade level structure or the construction, enlargement or closing of any additional schools unless: 1. Such action would further the goal of desegregating LRSD or eliminating the vestiges of past discrimination to the extent practicable; or, 2. The LRSD Board of Directors determines (i) that the educational benefits expected from such action substantially outweigh any adverse effects of the proposed action, (ii) that no practical alternative to the proposed action exists which will accomplish the educational objective, and (iii) that to the extent practicable measures will be initiated to counteract any adverse affects of the proposed action. G. Racial Balance. This Revised Desegregation and Education Plan recognizes that the desegregation of LRSD to the extent practicable does not require that every LRSD school be racially balanced. Accordingly, nothing in this Revised Desegregation and Education Plan shall be construed as requiring a particular racial balance at every LRSD school or as obligating LRSD to recruit students to obtain a particular racial balance in every LRSD school. IV. lnterdistrict Schools. LRSD and the Pulaski County Special School District ("PCSSD") shall operate Interdistrict Schools in accordance with the following: A. PCSSD lnterdistrict Schools. PCSSD shall operate Baker Elementary, Clinton Elementary, Crystal Hill Elementary and any new elementary school constructed in Chenal Valley as Interdistrict Schools; B. LRSD lnterdistrict Schools. LRSD shall operate King Elementary, Romine Elementary and Washington Elementary as lnterdistrict Schools; 7 C. Racial Composition. The ideal composition at interdistrict schools shall be as close to 50%-50% as possible with the majority race of the host district remaining the majority race at the Interdistrict School; D. Reserved Seats. PCSSD shall reserve at least 200 seats at Clinton Elementary and up to 399 seats at Crystal Hill Elementary for interdistrict transfer students from LRSD; E. Recruitment. LRSD and PCSSD agree to implement programs at Interdistrict Schools designed to attract interdistrict transfers and to work cooperatively to recruit interdistrict transfers to Interdistrict Schools; F. Outside Students. Interdistrict Schools shall be open to students who reside outside Pulaski County where the acceptance of the transfer will assist the Interdistrict School in achieving its ideal racial composition; and, G. Transportation. Transportation shall be provided by the home district for interdistrict transfers from Pulaski County to Interdistrict Schools. V. Student Achievement. A. Early Childhood Education. LRSD shall implement an early childhood education program which shall include a HIPPY program and a four year-old program with no less than 720 seats. B. Reading/Language Arts. 1. Primary Grades. LRSD shall implement the following strategies to improve academic achievement of students in kindergarten through the third grade: a. Establish as a goal that by the completion of the third grade all students will be reading independently to make accurate meaning out of words on a page; 8 b. Focus teaching efforts on reading/language arts instruction by teaching science and social studies content through reading/language arts and mathematics experiences; c Promote thematic instruction; d. Identify clear objectives for student mastery of all three reading cueing systems (phonics, semantics and syntax) and of knowing-how-to-learn skills; e. Monitor the appropriateness of teaching/learning materials to achieving curricular objectives and the availability of such materials in all classrooms; f. Establish uninterrupted blocks of time for reading/language arts and mathematics instruction; g. Monitor student performance using appropriate assessment devices; h. Provide parents/guardians with better information about their child's academic achievement; 1. Provide pre-kindergarten, kindergarten and first grade learning readiness experiences for students who come to school without such experiences; J. Train teachers to manage successful learning for all students in diverse, mainstreamed classrooms; and, k. Use the third and/or fourth grade as a transition year from focused reading/language arts and mathematics instruction to a more traditional school day. 2. Intermediate Grades. LRSD intends to implement the following strategies to improve the academic achievement of students in grades four and six: a. Adopt as a goal that by completion of the sixth grade all students 9 will master and use daily higher level reading comprehension skills for learning in all subject areas, for making meaning in real life experiences and for personal growth and enjoyment; b. Promote thematic instruction; c. Establish uninterrupted blocks of time for reading/language arts, mathematics, science and social studies instruction; d. Monitor the appropriateness of teaching/learning materials to achieving curricular objectives and the availability of such materials in all classrooms; e. Monitor student performance using appropriate assessment devices; f. Provide parents/guardians with better information about their child's academic achievement; and, g. Train teachers to manage successful learning for all students in diverse, mainstreamed classroom. 3. Secondary Schools. LRSD intends to implement the following strategies to improve the academic achievement of students in grades six2 through twelve: a. Adopt as a goal that upon graduation all students will read independently to make meaning in all subjects areas every day as necessary to be successful workers, citizens and life-long learners: b. Establish specific reading comprehension learning objectives for the language arts, mathematics, science and social studies curricula; c. Revise the language arts curriculum to include greater emphasis on 2LRSD recognizes that the sixth grade was previously included as an intermediate grade. The sixth grade is also included here since it will be a transition year into middle school. 10 reading for meaning and on expressing comprehension of reading through writing and speaking; d. Expand the use of a second Language Arts class at all secondary grade levels and establish procedures for identifying eligible students and, where practical, assigning students to their regular Language Arts teachers; e. Provide appropriate training to secondary teachers for implementation of these strategies; f. Monitor student progress and achievement using appropriate assessment devices. C. Mathematics. LRSD shall implement the following strategies to improve mathematics instruction: 1. Revise the mathematics curriculum to include a smaller number of concepts at each level, the use of manipulatives and problem solving and critical thinking and train teachers on its implementation; 2. Develop appropriate assessment devices for measuring individual student achievement and the success of the revised curriculum; 3. Provide resources for early intervention with students with mathematical problems and for training teachers on early intervention; and, 4. Revise the mathematics curriculum to increase the number of students successfully completing Algebra I and higher level mathematics courses. D. Funding. LRSD shall continue to provide additional funding to Franklin, Garland, Mitchell, Rightsell and Rockefeller elementary schools in accordance with the current formula as described 11 in August 16, 1995 report of the Office of Desegregation Monitoring. E. Alternative Education. LRSD shall provide alternative educational opportunities to the extent practicable for those students unable to succeed in a traditional learning environment. F. Parental and Community Involvement. LRSD shall establish a parental and community relations linkage system to facilitate parental and community involvement in LRSD schools and the operation of LRSD. VI. Teacher Assignments. A. Beginning in the 1998-99 school year and for the term of this Revised Desegregation and Education Plan, LRSD reserves the right to reassign teachers and/or prohibit teacher transfers as reasonably necessary to ensure: 1. that to the extent practicable the percentage of African-American certified personnel in each LRSD school is within plus or minus fifteen percentage points from the percentage of African-American certified personnel in the district as a whole; and, 2. that to the extent practicable the certified personnel at one race, African- American schools (2.. 90% African-American) is comparable w~th the certified personnel at other LRSD schools with regard to years of teaching experience and number of teachers with advanced degrees. B. Reasonably Necessary. Reassigning and/or prohibiting the transfer of a teacher shall not be reasonably necessary where the desegrative impact would be substantially outweighed by the educational benefits of allowing a teacher to remain in his or her present assignment or to transfer to another assignment. 12 VII. LRSD Compliance Program. LRSD shall implement a desegregation compliance program which shall include the following components: A. Compliance standards and procedures reasonably capable of reducing the prospect of noncompliance; B. Oversight of compliance with such standards and procedures by the Superintendent; C. Communication of compliance standards and procedures to all employees; D. Utilization of monitoring and auditing systems reasonably designed to detect noncompliance; E. Utilization of a reporting system whereby employees can report noncompliance without fear of retribution, including an employee hotline; F. Enforcement of compliance standards and procedures through appropriate disciplinary mechanisms, including the discipline of individuals responsible for the failure to report noncompliance; and, G. After noncompliance has been detected, implementation of all reasonable steps to correct past noncompliance and to prevent further noncompliance, including modification of the compliance program as necessary to prevent and detect further similar noncompliance. VIII. Plan Modification Process. Before filing with the district court a proposed modification of this Revised Desegregation and Education Plan, LRSD shall follow the procedure set forth below: A. LRSD shall submit to the other parties and to the Office of 13 Desegregation Monitoring ("ODM") its proposed modification along with an explanation of the circumstances justifying modification and the educational and financial impact of the proposed modification. B. Comment Period. Along with its notice of the proposed modification, LRSD shall establish a reasonable period of time (no less than ten days) for the parties and ODM to submit comments, recommendations or suggestions related to the proposed modification. C. Recommendation and Response. After the close of the comment period, LRSD shall file with the district court and serve on the parties its recommended modification and, at LRSD's discretion, a response to comments made by the parties and ODM. D. Hearing. Absent good cause shown, no party shall be permitted to raise an issue in opposition to LRSD's recommended modification unless that issue was raised by the party during the comment period. IX. Continuing Jurisdiction. A. General Rule. The district court shall have continuing jurisdiction to address issues regarding compliance with and modifications of this Revised Desegregation and Education Plan during its term. Nothing in this Revised Desegregation and Education Plan shall effect the district court's jurisdiction to enforce the Settlement Agreement with the exception of the Pooling Agreement. B. Process For Raising Compliance Issues. Before requesting the district court exercise its jurisdiction with regard to a compliance issue, the party seeking to raise the issue shall follow the procedure set forth below: 1. The party shall as soon as reasonably practicable give the LRSD 14 Superintendent or his designee specific written notice which includes the following: a. the paragraph(s) of this Revised Desegregation and Education Plan at issue; b. the names of all students involved, if any; c. the names of all LRSD agents or employees involved, if any; d. all facts of which the party is aware relevant to the compliance issue; and, e. a copy all documents in party's possession relevant to the compliance issue. 2. The written notice 1s intended to provide LRSD with all relevant information related to the compliance issue known to the parry so that LRSD can assess its compliance on the same basis the party. 3. LRSD shall conduct a reasonable investigation of the alleged noncompliance and shall provide the party a written response within thirty (30) days of receipt of written notice from the party or such later time as agreed. 4. If the party is unsatisfied with LRSD's response, the party shall within 30 days of receipt of LRSD's response submit the compliance issue to ODM or the district court's designee for facilitation of an agreement between the parties. 5. If the compliance issue remains unresolved after good faith attempts at facilitation by ODM or the district court's designee, the party may seek resolution of the issue before the district court. 6. Unless and until ordered to do otherwise by the district court, LRSD shall 15 be free to implement the programs, policies and procedures the party alleges fail to comply with - this Revised Desegregation and Education Plan. The term of this Revised Desegregation and Education Plan shall be three (3) school years beginning the 1998-99 school year and ending on the last day of classes of the 2000-01 school year. XI. Transition. The 1997-98 school year shall be a transition year in preparation for implementation of this Revised Desegregation and Education Plan. During this transition period, LRSD shall implement the May 1992 Desegregation Plan and Interdistrict Desegregation Plan to the extent they are consistent with this Revised Desegregation and Education Plan. However, there shall be no ODM monitoring or litigation concerning LRSD's implementation of the May 1992 Desegregation Plan or the Interdistrict Desegregation Plan. Rather, ODM shall monitor LRSD's preparation for implementation of the Revised Desegregation and Education Plan and act as a resource for LRSD in that process. XII. Unitarv Status. At the conclusion of the 2000-01 school year, the district court shall enter an order releasing LRSD from court supervision and finding LRSD unitary with regard to all aspects of school operations provided that LRSD has substantially complied with its obligations set forth in this Revised Desegregation and Education Plan. 16 FRIDAY, ELDRED GE & CLARK 1411SCH(L H. FIIIOAY (11221114} WILLIAM H. IUTTON , , .A . .IAM(S W . WOOIIE IYIION M. EIS(MAN . .lllll . , P'.A . .10 D. IELL. P' .A . A l'ARTNERSHIP OF INDIVIDlfALS AND l'ROFESSIONAL ASSOCIATIONS ATTORNEYS AT LAW C . ECHOLS . ,. . A . SA. IUTTllllY , ,. .A . ElllllCl S . UIISEllllY , l".A . LAllllZEUllllE, P' .A . OSCAII E. OAVl8 , .IA ., , . A . JAMES C . CLAAl , JA .. l".A . THOMAS, . LEGGETT, l" .A . JOHN O[W[Y WATSON, P' .A . ,AUL I . IENHAM Ill , l" .A. LAIIIIY W. IUllll , fl . A . A. WYCI.LIFF NISl[T , Jl't ., fl . A. JAMES EOWAl'IO HA.lllll'IIS, l" . A . J . l'HILLII" MALCOM , l" .A . JAME M. SIMl'SON, l" .A . JAMES M. SAXTON , , .A . J . SHErH[l'IO l'IUIIELL Ill , fl . A. DONALD H. IACON . l" .A . WILLIAM THOMAS IAXT11 . ,. .A . WALTER A . l"AULSON II , l" .A . IAIIIIIY E. COl"LIN , l" .A . lllllCHAIIO 0 . TAYLOR , P' .A . JOIEl'H I . HURST, Jfl . , fl .A . [LIZAIETH IIOll[N MUflllllAY , , . A . CHfllSTO,HEl't HELLER , , . A . LAUllllA HENSLEY SMtTH , , . A . IIOIUIT I . SHAF[llll , fl .A . WILLIAM M. GIIIFFIN Ill , fl.A. MICHAELS . MOORE , l" .A . DIANE 9 . MACl.[Y , , .A. WAL TOI M. EIEL Il l , l" .A . I.EVIN A . CIIASS , l" . A . WILLIAM A . WADDELL, JII ., l" .A . John W. Walker JOHN W. WALKER, P.A. 1723 Broadway Little Rock, AR 72206 2000 FIRST COMMERCIAL BUILDING <400 WEST CAPITOL AVENUE LITTLE ROCK, ARKANSAS 72201-3-413 TELEPHONE 501-378-2011 FAX NO . 501-378-21<47 June 5, 1997 Re: Little Rock School District Work Teams Dear John