Court filings: District Court, order; District Court, Little Rock School District's (LRSD's) amended motion for attorneys' fees and costs; District Court, joint motion to relieve Arkansas Department of Education (ADE) from its obligation to file a February 1999 semiannual monitoring report; District Court, opposition of Joshua intervenors to join motion; District Court, notice of filing, Arkansas Department of Education (ADE) project management report

The transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors. RECEIVED NOV C 1998 Orf!CE OF DESEGREGATION MONITORING IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, Plaintiff, vs. PULASKI COUNTY SPECIAL DISTRICT No. 1, et al., * * * * * * No. LR-C-82-866 * * * * * * * Defendants. * MRS. LORENE JOSHUA, et al., Intervenors, KATHERINE KNIGHT, et al., Intervenors, * * * * * * * * * * ORDER FILED U.S. OISTR1crcouRT EASTERN DISTRICT ARKANSAS NOVO l 1998 - JAMES W/ McGO~MACK, CLERK By: \ , C::hl (\ MUC\ ' DEP Cl.ERK . On July 1, 1998, the Court of Appeals of the Eighth Circuit handed down an opinion on the issue of funding of retirement and health insurance for teachers and directed this Court to decide, in the first instance, exactly what relief is appropriate. The Eighth Circuit's mandate was filed in this Court on August 17, 1998, and the parties have now submitted papers setting forth their respective views on the matter. Accordingly, a hearing on this issue is hereby scheduled for Tuesday, January 5, 1999, at 9:00 a.m. 1 IT IS SO ORDERED this J ~ay of November 1998. rHIS DOCUMENT ENTERED ON DOCKET SHEET IN COMPLIANCE WITH RULE 58 ANO/OR 79(a) FRCP ON l/-.!1;98 BY :n:: _ 1 The Court contacted a majority of the counsel in this case in an attempt to set an earlier hearing date but was infonned that counsels' schedules prevented such an earlier hearing. The Eighth Circuit has previously indicated that it expects some kind of hearing to be held on many of the issues in this case. See Little Rock School Dist. v. Pulaski Co. Spec. School Dist., 60 F.3d 435, 436-67 (80, Cir. 1995). 2 - HERSCHEL H . FRIDAY 11922 - 199-41 WILLIAM H . SUTTON , P. A . JAMES W . MOORE BYRON M . EISEMAN , JR .. P.A . JOE O. &Ell , P. A . .. C. ECHOLS, P. A . SA . BUTTRY , P. A . ERICK$ . URSERY , P. A . RE . DAVIS , JR ., P. A . JAMES C. CLARK , JR ., P. A . THOMAS P. LEGGETT , P. A . J OHN DEWEY WATSON , P. A . PAUL B, BENHAM Ill , P. A . LARRY W . BURKS , P. A . A . WYCKLIFF NISBET, JR ., P. A . JAMES EDWARD HARRIS , P. A . J . PHILLIP MALCOM, P. A . JAMES M . SIMPSON , P. A . JAMES M . SA X TON , P. A . J . SHEPHERD RUSSELL Ill, P. A . DONALD H. BACON , P. A . WILLIAM THOMAS BAXTER , P . A . BARRY E. COPLIN , P. A . RICHARD 0 . TAYLOR, P. A . JOSEPH 8 . HURST , JR ., P. A . ELIZABETH ROBBEN MURRAY , P. A . CHRISTOPHER HELLER, P. A . LAURA HENSLEY SMITH , P. A . ROBERTS . SHAFER, P.A . WILLIAM M . GRIFFIN Ill , P. A . MICHAELS. MOORE, P. A . DIANE S. MACKEY, P. A . WALTER M . EBEL Ill , P.A . KEVIN, A . CRASS , P. A. Wlllf:A.M A . WADDELL, JR ., P. A . FRIDAY, ELDREDGE & CLARK A PARTNERSHIP OF INOIVIOUALS ANO PROFESSIONAL ASSOCIATIONS ATTORNEYS AT LAW 2000 REGIONS CENTER 400 WEST CAPITOL LITTLE ROCK, ARKANSAS 72201 -3493 TELEPHONE 501 - 376 -2011 FAX NO . 501 - 376 -2147 November 12, 1998 NO\J 13 1998 Qff\CEOf o~sa;RtGA1\0N MOtt\lOR11'G Mr. Timothy G. Gauger Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, AR 72201 Re: Amended Fee Petition Dear Tim: SCOTT J. LANCASTER , P. A . M . GAYLE CORLEY , P. A . ROBERT 8 . BEACH , JR ., P. A . J . LEE BROWN , P. A . JAMES C . BAKER, JR .. P.A . HARRY A. LIGHT , P. A . SCOTT H . TUCKER , P. A. JOHN CLAYTON RANDOLPH , P. A . GUY ALTON WADE , P. A . PRICE C . GARONER , P. A . TONIA P. JONES , P. A . DAVID 0 . WILSON , P. A . JEFFREY H . MOORE, P. A . DAVID M . GRAF , P. A . CARLA GUNNELS SPAINHOUR. P.A JOHN C . FENDLEY , JR ., P. A . R. CHRISTOPHER LAWSON GREGORY 0 . TAYLOR TON Y L. WILCOX FRANC . HICKMAN BETTY J . DEMORY BARBARA J . RAND LYNDA M . JOHNSON JAMES W . SMITH CLIFFORD W. PLUNKETT DANIELL. HERRINGTON K. COLEMAN WESTBROOK, J R. ALLISON J . CORNWELL TODD A . GREER ELLEN M . OWENS HELENE N . RA YDER JASON B. HENDREN SUSANN . CHILDERS BRUCE 8 . TIDWELL CHRIS A . AVERITT Of COUNSH WILLIAM J . SMITH 8 . S. CLARK WILLIAM L. TERRY WILLIAM L. PATTON , JR . H. T . LARZELERE , P. A . WRITER 'S OIRl!CT NO. (501) 370-1506 I have enclosed our amended fee petition concerning the teacher retirement and health insurance issues . Much of my time was mistakenly left out of the original petition. The problem became apparent to me as I reviewed Sam's and Steve's fee petitions. It took some time for me to retrieve the time records from a general billing number. I apologize for the delay. CJH/k cc: All Counsel Ann Brown - ---- - --- - - Heller IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT V. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL l\1RS. LORENE JOSHUA, ET AL KATHERINE KNIGHT, ET AL RECEIVED NOV 1 3 1998 OfflCEOf DESEGREGATION MONffORINS LITTLE ROCK SCHOOL DISTRICT'S AMENDED MOTION FOR ATTORNEYS' FEES AND COSTS For its amended motion, the Little Rock School District (LRSD) states: PLAINTIFF DEFENDANTS INTER VEN ORS INTER VEN ORS 1. LRSD is the prevailing party with respect to the teacher retirement and health insurance issues and is therefore entitled to an award of attorneys' fees and costs. LRSD, together with the Pulaski County Special School District and the North Little Rock School District, moved for summary judgment because the State of Arkansas changed its method of funding teacher retirement and health insurance to their detriment and in violation of the settlement agreement in this case. This court granted summary judgment. On July 1, 1998, the Eighth Circuit Court of Appeals affirmed this court's order. 2. LRSD now seeks its attorneys' fees and costs expended presenting these issues. LRSD respectfully requests that this court award it reasonable attorneys' fees and costs. 3. The Eighth Circuit Court of Appeals has previously held in this case that fees should be awarded to LRSD for successful litigation enforcing the terms of its settle~ent agreement with the State of Arkansas. Little Rock School Dist. v. State of Ark., 127 F.3d 693 (8th Cir. 1997). 4. Friday, Eldredge & Clark has historically billed the Little Rock School District at significantly discounted rates. LRSD is nevertheless entitled to an award of reasonable fees at the rates normally charged by the attorneys who work on behalf of the district. Little Rock School Dist. v. State of Ark., 127 F.3d 693, 697-98 (8th Cir. 1997); Little Rock Sch. Dist. v. Pulaski County Special Sch. Dist. No. 1, 959 F.2d 716 (8th Cir. 1992). 5. LRSD should be awarded the following fees in accordance with the accompanying Affidavit: Christopher Heller - 114.75 hours x $170.00 = $19,507.50. 6. The district court has previously awarded fees to counsel for LRSD at the rate of $160 per hour for work done in 1994 and 1995. Order, December 31, 1997, Docket No. 3101. The fees sought in this petition are calculated at the regular rates for LRSD's lawyer for 1997 and 1998. The Eighth Circuit Court of Appeals has awarded fees to LRSD's lawyer at the rates requested in this petition. 7. LRSD's previous motion for attorneys' fees and costs related to these issues contained significant omissions which were brought to counsel's attention upon the filing of the North Little Rock School District and Pulaski County Special School District fee Affidavits. Counsel for ADE was promptly notified that the previous fee petition was incomplete and that an amended fee petition would be filed. F:IHOME\KATHY\APPEAL\1794USDCFccsAmdMot 2 WHEREFORE, LRSD prays for an award of reasonable attorneys' fees of $19,507.50 as set forth in the accompanying Affidavit. Respectfully submitted, LITTLE ROCK SCHOOL DISTRICT FRIDAY, ELDREDGE & CLARK 2000 Regions Bank Bldg. 400 West Capitol Avenue Little Rock, AR 72201 501/376-2011 CERTIFICATE OF SERVICE I certify that a copy of the foregoing Little Rock School District's Amended Motion for Attorneys' Fees and Costs has been served on the following on this 12th day of November, 1998: 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 Avenue Little Rock, AR 72201 F:IHOMEIKATHYIAPPEAL\179-IUSDCFeesAmdMot 3 Mr. John W. Walker JOHN W. WALKER, P.A. 1723 Broadway Little Rock, AR 72201 Mr. Richard Roachell ROACHELL LAW FIRM First Federal Plaza 401 West Capitol, Suite 510 Little Rock, AR 72201 Ms. Ann Brown Desegregation Monitor Heritage West Bldg., Suite 510 201 East Markham Street Little Rock, AR 72201 Mr. Timothy G. Gauger Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, AR 72201 Mr. James M. Llewellyn, Jr. Thompson & Llewellyn, P.A. 412 South 18th Street P.O. Box 818 Fort Smith, AR 72902-0818 F:IHOMEIKATHYIAPPEAL\1794USDCFecsAmdMo< 4 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRJCT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRJCT V. LR-C-82-866 PULASKI COUNTY SPECIAL SCHOOL DISTRJCTNO. 1, ET AL MRS. LORENE JOSHUA, ET AL KATHERJNE KNIGHT, ET AL AFFIDAVIT I, Christopher Heller, after being duly sworn, state under oath: REC IVED NOV 1 3 1998 OFFICE OF l&GREGATION MONITORING PLAINTIFF DEFENDANTS INTER VEN ORS INTERVENORS 1. Friday, Eldredge & Clark's billing statements attached as Exhibit A to this Affidavit reflect the hours worked on the teacher retirement and health insurance issues as recorded in contemporaneous time records. All of the time shown on these billing statements has been billed to the Little Rock School District and those bills have been paid. 2. I have been engaged in the private practice oflaw at Friday, Eldredge & Clark for seventeen years. My normal hourly billing rate for the period oftime covered by these issues was $170. 00. That rate is in line with the rates typically charged by lawyers of similar experience and ability in Pulaski County, Arkansas. I was recently awarded fees at this rate for work on these issues in the Eighth Circuit Court of Appeals. 3. Friday, Eldredge & Clark-has historically billed the Little Rock School District at significantly discounted rates. For the period of time covered by these issues, the highest hourly rate charged by any partner in the firm for any work on behalf of the Little Rock School District was $125.00, regardless of the partner's experience, ability or regular billing rate. 4. Based on the hours devoted to these appeals multiplied by the regular hourly rates of the participating lawyers, LRSD is entitled to the following fees: Christopher Heller - 114.75 hours x $170.00 = $19,507.50. By: - County of Pulaski) )ss. State of Arkansas) SUBSCRIBED AND SWORN to before me a Notary Public in and for the County of Pulaski, State of Arkansas on this ;.;,... ti- day of November, 1998. Respectfully submitted, LITTLE ROCK SCHOOL DISTRICT F:IHOME\KA THY\APPEAL11794USDCFeesAmdAlf 2 - - FRIDAY, ELDREDGE & CLARK 2000 Regions Bank Bldg. 400 West Capitol Avenue Little Rock, AR 72201 501/376-2011 CERTIFICATE OF SERVICE I certify that a copy of the foregoing Little Rock School District's Amended Motion for Attorneys' Fees and Costs has been served on the following on this 12th day of November, 1998: 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 Avenue Little Rock, AR 72201 Mr. John W. Walker JOHNW. WALKER, P.A. 1 723 Broadway Little Rock, AR 72201 Mr. Richard Roachell ROACHELL LAW FIRM First Federal Plaza 401 West Capitol, Suite 510 Little Rock, AR 72201 F:IHOMEIKATHY\APPEAL\1794USDCFccsAmdAff 3 Ms. Ann Brown Desegregation Monitor Heritage West Bldg., Suite 510 201 East Markham Street Little Rock, AR 72201 Mr. Timothy G. Gauger Office of the Attorney General 323 Center Street 200 Tower Building Little Rock, AR 72201 Mr. James M. Llewellyn, Jr. Thompson & Llewellyn, P.A. 412 South 18th Street P.O. Box 818 Fort Smith, AR 72902-0818 F:IHOME\KA THY\APPEALll 794USDCFecsA111Aff 4 LETTER TO DR. ROSSELL ENCLOSING DATA TELEPHONE CONFERENCE WITH AUDRY LEE RE: HISTORICAL STUDENT ASSIGNMENT DATA 4/29/96 CJH TELEPHONE CONFERENCE WITH DR. WILLIAMS RE: TEST SCORE DISPARITY/LOAN ISSUE TELEPHONE CONFERENCE WITH STACEY PITTMAN TELEPHONE CONFERENCE WITH DR. WILLIAMS VARIOUS MATTERS RE: UNITARY STATUS 4/29/96 JCF TELEPHONE CONFERENCE WITH DAVID BESON RE: MEETING 4/29/96 JLM TELEPHONE CONFERENCE WITH MS. LEWIS RE: MGMT TOOL TRAVELED TO LRSD; CONFERRED WITH DR. JACKSON AND MS. LEWIS RE: MGMT TOOL; RETURNED TO OFFICE 4/30/96 CJH TELEPHONE CONFERENCE WITH DR. WILLIAMS (2 CALLS) TELEPHONE CONFERENCE WITH RUSS MAYO RECEIVED & REVIEWED INFORMATION RE: SCALE TEST SCODES; ADE LOAN AGR MEMO FROM DR. MAYO RE: HEARINGS ON COMPLIANCE RECEIVED & REVIEWED REVISED BUSINESS CASES REVIEWED TRANSCRIPTS AND OLD FILES RE: 6 YEAR PLAN ARGUMENT CONFERENCE WITH JCF RE: MEETINGS AND MOTION RE: PLAN TERM (2) 4/30/96 JCF FAX FROM DR. MAYO RE: INTERNAL COMPLIANCE AUDIT TELEPHONE CONFERENCE WITH DR. ROSSELL RE: RESEARCH ON ORFIELD AND WALBERG 4/30/96 JLM PREPARATION OF NOTICE OF FILING; CORRESPONDENCE; REVIEWE AND FINALIZED; VARIOUS MATTERS RE: PROJECT MGMT TOOL 5/01/96 CJH LETTER FROM ELIZ TURNER RECEIVED & REVIEWED ADE PROJECT MGMT TOOL TELEPHONE CONFERENCE WITH SAM JONES RE: ADE MEETING TELEPHONE CONFERENCE WITH DR. WILLIAMS Page Inv# Date LI230 HOURS 1.00 .25 .25 .25 .25 .75 .25 .25 1.00 .50 .25 .50 .25 .75 1. 25 .50 .25 .50 1.00 .25 .so 27 -128658 6/30/96 .000090-CJH Gi) (Continued on page 28) 5/15/96 CJH 5/15/96 JCF 5/16/96 CJH 5/16/96 JCF 5/17/96 CJH 5/17/96 JCF 5/17/96 RSS WILLIAMS RE: INTERVENTION IN DESEG. CASE REVIEWED ARMOR ARTICLES AND CASES IN WHICH TESTIFIED; PREPARATION FOR TESTIMONY OF DR. ARMOR PREPARATION AND COURT HEARING EXPERT WITNESS DAVID ARMER; CONFERENCE WITH CO-COUNSEL; PREPARATION BRIEF TELEPHONE CONFERENCE WITH PAT GEE CONFERENCE WITH CJH RE: ARMOR TESTIMONY PREPARATION OF MOTION TO END JURISDICTION ATTENDED HEARING RE: TESTIMONY OF DR. ARMOR TELEPHONE CONFERENCE WITH DR. MAYO TELEPHONE CONFERENCE WITH ATTORNEY WALKER; THEN WALKER AND J. WRIGHT; CALLS TO SAM AND STEVE; CALL TO WILLIAMS AND MAYO TELEPHONE CONFERENCE WITH STACY PITTMAN TELEPHONE CONFERENCE WITH DEANNA RE: BEACH REQUEST TELEPHONE CONFERENCE WITH DR. MAYO RE: DOCUMENTATION OF SPECIFIC COMPLIANCE AREAS RESEARCHED AND PREPARATION OF BRIEF RE: COMPLIANCE; JURISDICTION REVIEWED TRANSCRIPTS RE: SIX YEAR ARGUMENT PREPARATION OF MOTION FOR END OF JURISDICTION MEETING WITH ADE, PCSSD, NULRSD AND LRSD RE: NEW STATE FUNDING FORMULA: THEN CONFERENCE WITH DISTRICT COUNSEL RESEARCHED AND FINAL PREPARATION AND REVISION OF MOTION AND BRIEF RE: FED. CT. JURISDICTION; REPORTED TO CLIENTS TELEPHONE CONFERENCE WITH SCOTT TROTTER'S OFFICE PREPARATION OF MOTION TO END JURISDICTION REVIEWED DRAFT BRIEF Page Inv# Date LI230 HOURS 2.00 2.50 9.50 .so .so 4.75 3.00 .25 1.00 .25 .25 .so 8.75 1.50 8.00 6.25 .25 7.50 .75 34 -128658 6/30/96 .000090-CJH (Continued on page 35) 5/29/96 JCF 5/29/96 JLM 5/30/96 CJH 5/30/96 JCF 5/31/96 CJH FEES LETTER FROM SAM JONES RE: COMM-CASE PREPARATION FOR ORFIELD TESTIMONY; REVIEWED ARTICLES AND CASES; CONFERENCE WITH CO-COUNSEL; AND TELEPHONE CONFERENCE WITH SAM JONES CONFERENCE WITH KRIS BABER LETTER FROM JOINT WALKER RE: DEPOSITIONS LETTER FROM JOINT WALKER RE: DEPOSITIONS CONFERENCE WITH CJH RE: HEARING PREPARATION REVIEWED ARTICLE BY ORFIELD RE: PREPARATION FOR HEARING TELEPHONE CONFERENCE WITH MARDI WATTS RE: ORFIELD TRANSCRIPT CONFERENCE CALL WITH DR. ROSSELL, CJH AND ATTY. SAM JONES RE: HEARING PREPARATION REVIEWED HISTORICAL STUDENT ASSIGNMENT NUMBERS; TELEPHONE CONFERENCE WITH AUDREY LEE RE: DATA ENTRY TRAVELED TO LRSD; ATTENDED MEETING RE: PROJECT MGMT TOOL: RETURNED TO OFFICE PREPARATION AND APPEARED AT TRIAL - EXPERT TESTIMONY OF GARY ORFIELD; THEN HEARING RE: DISCOVERY TELEPHONE CONFERENCE WITH DR. WILLIAMS LETTER FROM SAM JONES RE: PCSSD CLAIM LETTER FROM SAM JONES RE: M TOM ISSUE CONFERENCE WITH JUDGE WRIGHT RE: DEPOS. OF DR . WILLIAMS AND DR. MAYO ATTENDED HEARING; TESTIMONY OF DR. ORFIELD; LUNCH MEETING WITH CJH; ATTY. JONES REVIEWED MILLIKEN OPINIONS; CONFERENCE WITH CJH RE: PREPARATION FOR TESTIMONY Page Inv# Date LI230 HOURS .25 .25 8.50 .25 .25 .25 1.50 4.50 .25 1.25 1.25 1.00 9.75 .25 .25 .25 .75 7.00 OF ORFIELD 1.75 38 -128658 6/30/96 .000090-CJH PREPARATION AND APPEARED FOR HEARING G) RE: ADE FUNDING ISSUE RECEIVED & REVIEWED PCSSD FOIA REQUEST 5 (Continued on page 39) RECEIVED & REVIEWED ORDER RE: JOSHUA RESPONSE TELEPHONE CONFERENCE WITH J. WRIGHTS DOCKET CLERK RESEARCHED POSSIBLE CLAIMS VS ADE ER BREACH OF SETTLEMENT; CALL TO MARK MILHOLLEN 5/31/96 JCF ATTENDED HEARING RE: SCHEDULE ON FUNDING ISSUES ORGANIZED MATERIALS FOR EXPERT FILES USE DURING HEARINGS CONFERENCE WITH ATTY. STEVE JONES RE: FILING JOINT MOTION ON FUNDING ISSUES TELEPHONE CONFERENCE WITH BOB CONNOLLY RE: INCENTIVE SCHOOL ACHIEVEMENT DATA TELEPHONE CONFERENCE WITH MARK MILHOLLEN RE: PREPARATION FOR BUDGET HEARINGS 5/31/96 JLM PREPARATION OF PLEADING AND CORRESPONDENCE; VARIOUS MATERS RE: Page Inv# Date LI230 HOURS 39 -128658 6/30/96 .000090-CJH ~~ ~ .25 .25 .25 PROJECT MGMT TOOL Total Services 1.00 897.75 $86053.75 ANDREW T. TURNER CHRISTOPHER JOHN HELLER DEBORAH K. MOORE JOHN CLAYBURN FENDLEY JERRY LEE MALONE JANE MARIE WEISENFELS ROBERTS. SHAFER WALTER A. PAULSON WILLIAM H. SUTTON BINDING EXPENSE COURT REPORTER DISBURSEMENT RE: DEPOSITION EXPENSE EXPRESS MAIL COPY CHARGES FILE PREPARATION - - 1. 75 494.00 26.00 321.75 26.75 3.00 21.50 .50 2.50 X 85.00 = 148.75 X 105.01 = 51874.94 X 45.00 = 1170.00 X 85.00 = 27348.75 X 105.00 = 2808.75 X 45.00 = 135.00 X 105.00 = 2257.50 X 105.01 = 52.51 X 105.01 = 262.53 108.25 1371.00 17.00 2528.40 16.80 2335.20 126.00 {Continued on page 40) - - LITTLE ROCK SCHOOL DISTRICT MARKHAM & IZARD STREETS LITTLE ROCK AR 72201 Re: LRSD V. PULASKI CTY SPECIAL SCHOOL DIST NO. 1 5/28/96 CJH RECEIVED & REVIEWED PCSSD MOTION AND BRIEF 6/02/96 JCF REVIEWED BUSINESS CASES AND TENTATIVE 96-97 BUDGET 6/03/96 CJH LETTER FROM ELIZ BOYTER RECEIVED & REVIEWED ADE PROJECT MGMT TOOL PREPARATION AND MEETING WITH MARK MILHOLLEN RE: CLAIM AGAINST STATE: CONFERENCE WITH JCF RECEIVED & REVIEWED ORDER RE: FEES RECEIVED & REVIEWED DOCUMENTS FROM MILHOLLEN; RESEARCH AND PREPARATION OF CLAIM AGAINST STATE 6/03/96 JCF FAX FROM DR. ROSSELL RE: SERVICES CONFERENCE WITH MARK MILHOLLEN RE: NEW FUNDING FORMULA ISSUES TELEPHONE CONFERENCE WITH BOB CONNOLLY RE: INCENTIVE SCHOOL ACHIEVEMENT TELEPHONE CONFERENCE WITH AUDREY LEE RE: HISTORICAL STUDENT ASSIGNMENT DATA PREPARED FORMAT FOR INCENTIVE SCHOOL ACHIEVEMENT DATA; FAXED TO BOB CONNOLLY 6/04/96 CJH LETTER TO DR. JOEL ANDERSON LETTER TO BILL BEAVEN CONFERENCE WITH STEVE ENGSTROM RE: WALKER FEES; REVIEWED FILE; EXCHANGED INFORJATION; RECEIVED & REVIEWED FEE DOCUMENTS RESEARCHED AND PREPARATION OF MOTION AND BRIEF OF ADE Page Inv# Date LI230 HOURS .so 2.50 .25 .so e 65 2.50 .25 . 25 .so .25 .25 1.50 8 1 -129263 7/30/96 . 000090-CJH (Continued on page 2) 6/04/96 JCF 6/05/96 CJH 6/05/96 JCF 6/06/96 JCF 6/07/96 JCF 6/10/96 CJH 6/10/96 JCF PREPARATION AND MEETING WITH BIRACIAL COMM. PREPARATION OF MOTION TO EXCUSE RIGGS FROM BUDGET HEARING REVIEWED TRANSCRIPT OF LAST BUDGET HEARING; PREPARATION FOR BUDGET HEARING RESEARCHED AND PREPARATION OF LRSD MOTION AND BRIEF; CALL TO SAM JONES; DON STEWART; MARK MILHOLLEN, REVIEWED AND REIVSED; FILED RECEIVED & REVIEWED JOSHUA MOTION TO EXTEND RECEIVED & REVIEWED JOSHUA MOTION AND BRIEF RE: INCENTIVE SCHOOLS CONFERENCE WITH WITNESSES RE: PREPARATION FOR BUDGET HEARING REVIEWED BUDGET AND BUSINESS CASES; PREPARATION OF OUTLINE FOR BUDGET HEARING REVIEWED ENROLLMENT PROJECTIONS AND RECRUITMENT MATERIALS; PREPARATION FOR BUDGET HEARING ATTENDED BUDGET HEARING REVIEWED BUSINESS CASES; CONFERENCE WITH MR. MILHOLLEN RE: PREPARATION FOR BUDGET HEARING REVIEWED JOSHUA'S MOTION RE: INCENTIVE SCHOOLS LETTER FROM SAM JONES WITH REVISED BRIEF RECEIVED & REVIEWED NLRSD MOTION AND BRIEF LETTER FROM MR. GANS RE: ADE APPEAL RECEIVED & REVIEWED PCSSD REQUEST FOR PRODUCTION AND INTERROGATORY RESEARCHED AND PREPARATION FOR HEARING ON JOSHUA FEE ISSUE REVIEWED ODM AND JOSHUA REPORTS CITED IN JOSHUA MOTION - PREPARATION OF RESPONSE CONFERENCE WITH CJH RE: BUDGET HEARING PRINTED NEW 8TH CIR. OPINION RE: BURDEN Page Inv# Date LI230 HOURS 1.25 .25 3.75 G .25 .75 6.00 1. 50 6.75 .50 .25 @) 2.25 3.00 .25 2 -129263 7/30/96 .000090-CJH (Continued on page 3) INCENTIVE SCHOOL OBLIGATIONS 6/26/96 CJH TELEPHONE CONFERENCE WITH ED JACKSON; CLAY FENDLEY; REVIEWED DESEG. REPORTING REQUIREMENTS RESEARCHED AND PREPARATION OF FEE PETITION VARIOUS MATTERS RE: UNITARY STATUS DATA; MONITORING REPORTS: RESPONSE TO WALKER; REVIEWED NEW CASES 6/26/96 JCF CONFERENCE WITH DEANA RE: INCENTIVE SCHOOL RESPONSE CONFERENCE WITH CJH RE: PROGRAM PLANNING AND BUDGET TOOL REVIEWED PROGRAM PLANNING AND BUDGET TOOL FOR FY 97 AND FY 98 REVIEWD SUMMARY OF INCENTIVE SCHOOL OBLIGATIONS PREPARED BY DEANA TELEPHONE CONFERENCE WITH MS. LEWIS RE : PROGRAM PLANNING AND BUDGET TOOL CONFERENCE WITH DR. JACKSON AND MS. LEWIS RE: PROGRAM PLANNING AND BUDGET TOOL 6/27/96 CJH TELEPHONE CONFERENCE WITH SAM JONES RECEIVED & REVIEWED FAX FROM TIM GAUGER TELEPHONE CONFERENCE WITH MR. GAUGER RECEIVED & REVIEWED FAX FROM BOB MORGAN CONFERENCE WITH FENDLEY RE: SERVICEMASTER BRIEF PREPARATION OF MOTION RE: ATTORNEY FEES TELEPHONE CONFERENCE WITH TERESA CALDWELL TELEPHONE CONFERENCE WITH ATTORNEY KOWLER'S OFFICE 6/27/96 JCF PREPARATION OF NOTICE OF FILING PROGRAM PLANNING AND BUDGETING TOOL TELEPHONE CONFERENCE WITH JOY SPRINGER RE: JOSHUA MONITORING REPORTS TELEPHONE CONFERENCE WITH FRETA ROGERS RE: INCENTIVE SCHOOL ACHIEVEMENT DATA 6/28/96 CJH LETTER FROM ANGEL JONES WITH NOTICE RECEIVED & REVIEWED ADE MOTION 6/28/96 DKMP REVIEWED SUMMARY OF MONITORING REPORT Page Inv# Date LI230 HOURS .25 .75 2.25 1. 75 1.50 .50 1.00 3.50 .25 6 -129263 7/30/96 .000090-CJH db .25 .25 .50 .25 .25 .25 .25 .25 0 (Continued on page 7) - - LITTLE ROCK SCHOOL DISTRICT MARKHAM & IZARD STREETS LITTLE ROCK AR 72201 Re: LRSD V. PULASKI CTY SPECIAL SCHOOL DIST NO. 1 7/01/96 CJH TELEPHONE CONFERENCE WITH STEVE JONES 7/01/96 DKMP PREPARATION OF SUMMARY OF REPORTS 7/01/96 JCF RECEIVED AND REVIEWED ACHIEVEMENT DATA FROM FRETA ROGERS RECEIVED AND REVIEWED HISTORICAL STUDENT ASSIGNMENT DATA FROM AUDREY LEE TELEPHONE CONFERENCE WITH FRETA ROGERS RE: INCENTIVE SCHOOL ACHIEVEMENT REPORTS 7/02/96 CJH RECEIVED & REVIEWED ORDER RE: ADE RECEIVED & REVIEWED ORDER RE: FEE PETITION TELEPHONE CONFERENCE WITH SAM JONES REVIEWED EXPERT TRANSCRIPTS 7/03/96 CJH RECEIVED & REVIEWED JOSHUA MOTION AND BRIEF RE: ODM RECOMENDATIONS VARIOUS MATTERS RE: PLAN MODIFICATIONS; CONFERENCE WITH JCF; RESEARCHED APPEAL ISSUES R:E MOTION TO DISMISS/ SERVICEMASTER 7/03/96 JCF CONFERENCE WITH CJH RE: KANSAS CITY AGREEMENT; TELEPHONE CONFERENCE WITH MO. AG'S OFFICE 7/05/96 CJH REVIEWED TRANSCRIPTS RE: PLAN MODIFICATION 7/08/96 CJH TELEPHONE CONFERENCE WITH JIM HATHAWAY TELEPHONE CONFERENCE WITH DIXON FLAKE TELEPHONE CONFERENCE WITH MARK MILHOLLEN RE: HEARING REVIEWED INCENTIVE SCHOOL 4 YR OLD AND KINDERGARTEN INFORMATION; CALL TO Page Inv# Date LI230 HOURS .so 6.00 .25 . 25 ci95 d!, I 5 1.00 3.25 .25 1.00 .25 .25 .25 (Continued on 1 -131096 10/22/96 .000090-CJH page 2) CONFERENCE WITH CJH RE: MEETING TO DISCUSS MODIFYING STUDENT ASSIGNMENT PLAN CONFERENCE WITH CJH AND JULIE WIEDOWER RE: MODIFYING STUDENT ASSIGNMENT PLAN TELEPHONE CONFERENCE WITH DR. ARMOR RE: PREPARING NEW STUDENT ASSIGNMENT PLAN REVIEWED STUDENT ASSIGNMENT PLAN; PREPARED DRAFT MODIFICATIONS BASED ON EXPERT HEARINGS TELEPHONE CONFERENCE WITH JULIE WIEDOWER RE: MEETING TO DISCUSS MODIFYING STUDENT ASSIGNMENT PLAN REVIEWED MONITORING REPORTS; PREPARATION OF OUTLINE OF OBLIGATIONS RE: SCHOOL THEMES, MULITCULTURAL EDUC., FOREIGN LANG., SCIENCE LABS AND FIELD TRIPS 7/18/96 CJH RECEIVED & REVIEWED ORDER VARIOUS MATTERS RE: CREATION OF EXHIBITS IN SUPPORT OF UNITARY STATUS; PLAN MODICIATIONS TELEPHONE CONFERENCE WITH SAM JONES TELEPHONE CONFERENCE WITH MARK MILHOLLEN RESEARCHED AMEND 59, AMEN. 1 AND OTHER SCHOOL FINANCE ISSUES; CONFERENCE WITH SCHOOL DISTRICUT COUNSEL AND FINANCE OFFICIALS CONFERENCE WITH JCF RE: MOTIONS AND SCHEDULING 7/18/96 JCF REVIEWED AND REVISED OUTLINE OF OBLIGATIONS PREPARED BY DEANA RESEARCHED IMPACT OF SETTLEMENT AGREEMENT ON TERMINATION OF CONSENT DECREE TELEPHONE CONFERENCE WITH DEANA RE: PRINTING AUDIT RESULTS BY DOCUMENT PAGE NUMBER 7/19/96 JCF REVIEWED JOSHUA MOTION AND BRIEF RE: ODM RECOMMENDATIONS RESEARCHED POWER OF FEDERAL COURT TO Page Inv# Date LI230 HOURS .25 .75 1.00 1.25 .25 3.25 .25 1. so .25 .25 4 -131096 10/22/96 .000090-CJH @ .25 4.25 2.75 .25 .75 (Continued on page 5) SUA SPONTE MODIFY CONSENT DECREE REVIEWED ODM REQUIREMENTS RE: INCENTIVE SCHOOLS AND CORROLATED WITH LRSD OBLIGATION ID NUMBERS REVIEWED ORDER RE: JOSHUA MOTION RE: INCENTIVE SCHOOLS; PREPARATION OF MOTION TO EXTEND TIME TO RESPOND TO JOSHUA MOTION RE: ODM RECOMMENDATIONS 7/22/96 CJH TELEPHONE CONFERENCE WITH SAM JONES (2) TELEPHONE CONFERENCE WITH DR. WILLIAMS TELEPHONE CONFERENCE WITH DR. ANDERSON 7/23/96 CJH TELEPHONE CONFERENCE WITH SAM JONES (2) RESEARCHED INTERVENTION ISSUES TELEPHONE CONFERENCE WITH PAT GEE REVIEWED FURTHER REVIEW OF ADE DISCOVERY RESPONSES RECEIVED & REVIEWED PCSSD DRAFT INTERROGATORIES RECEIVED & REVIEWED ADE MOTIN TO DISMISS/ABSTAIN WITH BRIEF 7/23/96 JCF TELEPHONE CONFERENCE WITH PATTY KOHLER RE: RESCHLEY REPORT AND LRSD DATA 7/24/96 CJH TELEPHONE CONFERENCE WITH JULIE WEIDOMIER RE: S/A INFORMATION; LAIDLAW SOFTWARE FOR MANIP. S/A DATA TELEPHONE CONFERENCE WITH SAM JONES (2) RESEARCHED AND CONFERENCE WITH CO-COUNSEL RE: INTERVENTION; ROSS. DISCOVERY; RESPONSE LETTER FROM SAM JONES RECEIVED & REVIEWED PCSSD DISCOVERY DOCUMENTS 7/24/96 JCF TELEPHONE CONFERENCE WITH DR. JACKSON RE: BUDGETING TOOL 7/25/96 CJH LETTER FROM ANN BROWN RE: LRSD BUDGET LETTER FROM STEVE JONES RECEIVED & REVIEWED NLRSD MOTION AND BRIEF 7/26/96 CJH RESEARCHED WHITE FLIGHT ISSUES; NEW Page Inv# Date LI230 HOURS 1. 75 4.00 .50 GJ .25 0 .25 ~ .so 1.25 .25 .25 .75 ey .75 .25 .25 .25 .so 5 -131096 10/22/96 .000090-CJH (Continued on page 6) 8TH CIR. CASE TELEPHONE CONFERENCE WITH SAM JONES RE: ENDING ISSUES; INTERVENTION RESEARCHED ADE REGS AND STATUTES RE: SCHOOL FUNDING CONFERENCE WITH JCF (2) RE: RESEARCH ISSUES 7/28/96 CJH LETTER TO DR. ANDERSON RE: NLR MOTION REVIEWED DOCUMENTS PROVIDED BY ADE CONTINUED REVIEWED STATE PLEADINGS AND FILES RE: ADE FINANCIAL ISSUES 7/29/96 CJH RESEARCHED AND REVIEWED DOCUMENTS AND ADE PLEADINGS RE:O FUNDING AND INTERVENTION ISSUES TELEPHONE CONFERENCE WITH SAM JONES MEMO FROM SAM JONES RECEIVED & REVIEWED ANALYSIS OF ARK. SCHOOL FUNDING PLAN TELEPHONE CONFERENCE WITH PAT GEE 7/29/96 JCF REVIEWED GREY BOOK; REVIEWED FY 97 AND FY 98 BUDGET TOOL 7/30/96 CJH TELEPHONE CONFERENCE WITH SAM JONES VARIOUS MATTERS RE: ADE FUNDING ISSUES; COMPLIANCE; ODM REPORTS; GOOMED REPORT 7/31/96 CJH TELEPHONE CONFERENCE WITH DR. ANDERSON LETTER FROM SAM JONES LETTER FROM GUS TAYLOR RE: MEDIATION PREPARATION OF MOTION TO RELEASE SEATS TELEPHONE CONFERENCE WITH MARK MILHOLLEN RE: LAKE VIEW BUDGET 7/31/96 JCF PREPARATION OF NOTICE OF FILING OF BUDGET TOOL CONFERENCE WITH DR. JACKSON AND MS. LEWIS RE: BUDGET TOOL REVIEWED INCENTIVE SCHOOL PROGRAM; REVIEWED AUDIT OF OBLIGATIONS RE: PREPARATION OF RESPONSE TO JOSHUA MOTION RE: INCENTIVE SCHOOLS 8/01/96 CJH REVIEWED AND FINALIZED MOTION LETTER FROM ELIZ TURNER RECEIVED & REVIEWED ADE PROD MGMT TOOL Page Inv# Date LI230 HOURS 1.00 G <9 .50 .25 G;; ~ ~ .25 ~--2~0 1. 75 .25 .25 .25 .25 .25 .25 1.25 2.75 .50 .25 .50 6 -131096 10/22/96 .000090-CJH (Continued on page 7) RECEIVED & REVIEWED PCSSD DRAFT RESPONSE 8/01/96 JCF RESEARCHED APPOINTMENT OF RECEIVER TO INSURE COMPLIANCE WITH CONSENT DECREE REVIEWED AUDIT OF DESEG. OBLIGATIONS RE: PREPARATION OF RESPONSE TO JOSHUA MOTION RE: INCENTIVE SCHOOLS 8/02/96 CJH TELEPHONE CONFERENCE WITH GRAM JONES; RECEIVED REVISED DRAFT BRIEF; REVIEWED AND CORRECTION; CALL TO SAM TELEPHONE CONFERENCE WITH BARRY WARD RECEIVED & REVIEWED JOSHUA MEM. BRIEF OPPOSIVE END . OF FED JONES; CONFERENCE WITH JCF 8/02/96 JCF REVIEWED JOSHUA RESPONSE TO MOTION TO END JURISDICTION PREPARATION OF RESPONSE TO JOSHUA MOTION RE: INCENTIVE SCHOOLS PREPARATION OF EXTENSION OF TIME TO REPLY TO JOSHUA RESPONSE TO MOTION TO END JURISDICTION 8/05/96 CJH RECEIVED & REVIEWED PCSSD MOTION TO CLARIFY 1993 ORDER RECEIVED & REVIEWED PCSSD RESPONSE TO INTERVENTION MOTION, BRIEF IN SUPPORT; ANS RESPONSE TO ANSWER FILED BY POTENTIAL INTERVENTOR CONFERENCE WITH JCF RE: RESPONSE TO JOSHUA RE: COMPLIANCE (2) TELEPHONE CONFERENCE WITH SAM JONES TELEPHONE CONFERENCE WITH DENT GITCHER LETTER TO DENT GITCHER TELEPHONE CONFERENCE WITH STEVE JONES TELEPHONE CONFERENCE WITH COURT REPORTER RE: ORFIELD TRANSCRIPTS RECEIVED & REVIEWED BIRACIAL, COMM. MONITORING INST. VARIOUS MATTERS RE: RESPONSE TO JOSHUA OTIONS; RESEARCHED; PREPARATION OF RESPONSE 8/05/96 JCF CONFERENCE WITH CJH RE: INCENTIVE SCHOOL RESPONSE Page Inv# Date LI230 HOURS Q 2.25 2.50 G 1.50 1.00 6.50 .25 .50 .25 .25 .25 .50 3 . 25 .50 7 -131096 10/22/96 .000090-CJH (Continued on page 8) 8/06/96 CAAC 8/06/96 CJH 8/06/96 JCF 8/07/96 CJH 8/07 /96 JCF 8/08/96 CJH RESEARCHED STANDARD AND REMEDIES FOR CIVIL CONTEMPT COPIED CASES RECEIVED & REVIEWED NLRSD MOTION RECEIVED & REVIEWED PCSSD MOTION AND BRIEF RE: CLASS BRIEFS PREPARATION OF RESPONSE TO WALKER PLEADINGS; REVIEWED DRAFTS; CONFERENCE WITH FENDLEY RECEIVED & REVIEWED PCSSD RESPONSE TO ADE; BRIEF REVIEWED TRANSCRIPTS OF HEARING RE: JUNE 5, 1992 ODM REPORT PREPARATION OF DRAFT RESPONSE TO JOSHUA MOTION RE: ODM RECOMMENDATIONS PREPARATION OF BRIEF IN RESPONSE TO JOSHUA MOTIONS RE: INCENTIVE SCHOOLS RESEARCHED WHETHER FINDING OF CONTEMPT REQUIRED FOR COURT TAKE ENFORCMENT ACTION TELEPHONE CONFERENCE WITH STERLING INGRAM LETTER FROM TIM GAUGER RE: PRIVILEGE DOCUMENTS TELEPHONE CONFERENCE WITH BEVERLY (2 CALLS) TELEPHONE CONFERENCE WITH BARRY WARD TELEPHONE CONFERENCE WITH SAM JONES (2) RESEARCH CLASS ACTION ISSUES REVIEWED FY 96 BUDGET HEARING TRANSCRIPT RE: SPANISH PROGRAM PREPARATION OF BRIEF RE: JOSHUA MOTION ON ODM RECOMMENDATIONS RESEARCHED BURDEN OF PROOF ISSUE RE: JOSHUA MOTIONS RE: INCENTIVE SCHOOLS TELEPHONE CONFERNECE WITH STERLING INGRAM RE: MEETING ON JOSHUA MOTIONS AND SPANISH PROGRAM PREPARATION OF RESPONSES TO WALKER PLEADINGS RE : INCENTIVE SCHOOLS AND ODM, CONFERENCE WITH JCF AND REVIEWED AND REVISED DRAFTS Page Inv# Date LI230 HOURS 4.75 .75 .25 .so 1.00 GP 1.50 1.50 2.50 4.00 .25 .25 .so .25 1.00 .75 4.25 3.50 .25 1.00 8 -131096 10/22/96 .000090-CJH {Continued on page 9) RECONSTRUCTING SOFTWARE RECEIVED & REVIEWED JOSHUA OPPOSITION TO PCSSD MOTION RE: CLASS STILES RECEIVED & REVIEWED ADE RESPONSE. - INTERVENTION RECEIVED & REVIEWED ORDER RE: VARIOUS MOTIONS RECEIVED & REVIEWED KNIGHT MOTION RECEIVED & REVIEWED PCSSD FEE MOTION; BRIEF; AFFIDAVIT RECEIVED & REVIEWED PCSSD SUPPLEMENTAL TO PLAN MOD. MOTION EXHIBITS 8/20/96 CJH TELEPHONE CONFERENCE WITH SAM DAVIS RE: STATE HEARING TELEPHONE CONFERENCE WITH KENT GITENER TELEPHONE CONFERENCE WITH ED JACKSON RE: BIRACIAL ADK, REVIEWED FILE RECEIVED & REVIEWED ORFIELD TRANSCRIPT AND SENT COPY TO DENT GITCHELL, LARRY BARWAY 8/21/96 CJH RECEIVED & REVIEWED ADE RESPONSE TO PCSSD WITH BRIEF REVIEWED FOR AND PREPARATION FOR LAKEVIEW HEARING RECEIVED & REVIEWED PCSSD MANUAL FOR FEES AND COSTS 8/22/96 CJH ATTENDED CLASS CERT HEARING IN LAKE VIEW CASE; CONFERENCE WITH SAM JONES TELEPHONE CONFERENCE WITH MARK MILHOLLEN TELEPHONE CONFERENCE WITH SAM JONES (2); REVIEWED TRANSCRIPTS 8/22/96 JCF CONFERENCE WITH LARRY BURKLEY RE: STATUS PREPARATION OF NOTICE OF FILING 4TH QUARTER PBD TELEPHONE CONFERENCE WITH SHIRLEY LEWIS RE: 4TH QUARTER PBD REVIEWED AND SUMMARIZED VOLUME I OF TESTIMONY OF DR. DAVID ARMOR 8/23/96 CJH CONFERENCE WITH LR ADVANCE RE: VARIOUS DESEG AND STUDENT ASSIGNMENT ISSUES; Page Inv# Date LI230 HOURS .25 .25 .25 .25 .25 .50 .50 .50 .25 .50 .75 10 -131096 10/22/96 .000090-CJH (35 .75 .50 1. 75 .25 .50 .25 .25 2.50 (Continued on page 11) 8/23/96 JCF 8/25/96 CJH 8/26/96 CJH 8/26/96 JCF 8/27 /96 CJH CONFERENCE WITH JCF CONFERENCE WITH MARK MILHOLLEN RECEIVED & REVIEWED 1996-1997 FINAL BUDGET RECEIVED & REVIEWED TRANSCRIPT OF BUDGET HEARING RECEIVED & REVIEWED LRSD STATUS AND PROGRAM PLANNING DOCUMENTS PREPARATION OF RESPONSE TO MOTION TO INTERVENE TELEPHONE CONFERENCE WITH MARK MILHOLLEN RE: BUDGET TELEPHONE CONFERENCE WITH AUDREY LEE RE: ZONE BLOCK MAPS REVIEWED AND SUMMARIZED VOLUME II OF TESTIMONY OF DR. ARMOR CONFERENCE WITH CJH, STACEY PITTMAN AND BAKER KURRUS RE: IMPLEMENTING RECOMMENDATION OF ALLIANCE VARIOUS MATTERS RE: CLAIMS VS ADE; RESPONSES TO INTERVENORS; LAKE VIEW AND BUDGET ISSUES TELEPHONE CONFERENCE WITH SAM JONES; REVIEWED DRAFTS LETTER TO STERLING