The transcript for this item was created using Optical Character Recognition (OCR) and may contain some errors.  IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION LITTLE ROCK SCHOOL DISTRICT, ET AL. vs. LR-C-82-866 PLAINTIFFS :~~~~I COUNTY SPECIAL SCHOOL DISTRICTRECEIVED DEFENDANTS MRS . LORENE JOSHUA, ET AL. KATHERINE KNIGHT, ET AL. DEC ~ 1997 OFFICE OF PLAINTIFF LRSD, s AKiii~Ti MONITORING INT ERVEN ORS INTERVENORS THE JOSHUA INTERVENORS' FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING LRSD'S MOTION FOR APPROVAL OF THE REVISED DESEGREGATION AND EDUCATION PLAN Plaintiff Little Rock School District ( "LRSD") for its Answers to The Joshua Intervenors' First Set of Interrogatories and Requests for Production of Documents states: INTERROGATORY NO. 1: Please state the name, title, address and telephone number of each and every individual assisting in the preparation of the answers to these interrogatories. ANSWER: Objection. This interrogatory requests information which is privileged under the work product doctrine and/or the attorney-client privilege. Without waiving this objection, LRSD states that the following persons assisted in the preparation of these answers: Dr. Les Carnine, Christopher Heller and John c. Fendley, Jr. INTERROGATORY NO. 2: In 15 instances in paragraphs II. B. through II. P. of the proposed new plan, the words "LRSD shall implement programs policies and/or procedures" followed by a particular subject matter appear. Please identify separately for l:lhomollct'd lcy\lrod'dco-joob.ra  ' . each of these 15 paragraphs all programs, policies and procedures - which you maintain are currently implemented and are intended to be encompassed by the reference in the particular subparagraph of Part II. of the proposed plan. In addition, please specify when the implementation of the particular program, policy or procedure began. Lastly, as to each sub-paragraph, please indicate whether work is underway to develop a particular program, policy or procedure to implement the obligation and, if so, describe generally the nature of the initiative(s) and the anticipated completion date(s). ANSWER: Except as otherwise provided in LRSD's Revised Desegregation and Education Plan ("Revised Plan"), the obligations set forth in Section II were not intended to encompass any particular program, policy and procedure currently being implemented. As stated in Section XI of the Revised Plan, the 1997-98 school year will be a transition year in preparation for implementation of the Revised Plan during the 1998-99 school year. During the transition year, LRSD will be evaluating current programs, policies and procedures and developing new programs, policies and procedures to be implemented in order to meet its obligations under the Revised Plan. Some of this work has already been completed and is contained in the work team reports submitted to the LRSD Board of Directors in August of this year. INTERROGATORY NO. 3: Please explain the reason(s) that the proposed plan does not include in the 15 instances referred to in Interrogatory No. 2, or in any instance, the identification of the l:lh:>n-cllcndlcylll'ld'doo-jooh.,.. 2 particular programs, policies and procedures to be implemented. (If LRSD believes that there is identification of a particular standard in one or more instances, please answer as to obligations where you agree that there is no identification of a particular standard or program). ANSWER: The Revised Plan includes specific programs, policies and/or procedures with regard to student assignments (Section III & IV), African-American academic achievement (Section V), equitable allocation of certified personnel (Section VI) and compliance (Section VII). With regard to the remaining obligations, LRSD believes that, in order for the Revised Plan to be successful, the details related to implementation of the Revised Plan must be subject to modification without district court involvement. LRSD firmly believes that flexibility is essential to instilling in the - qistrict a sense of responsibility and accountability. INTERROGATORY NO. 4: Would the system refuse to support adoption of the revised plan if the plan included the identification of particular programs, policies and/or procedures, or other steps, to implement the "obligations" identified in Part II? If so, explain the reason(s) for the system's pos i tion. ANSWER: The Revised Plan does identify particular programs, policies and/or procedures. See Answer to Interrogatory No. 3. INTERROGATORY NO. 5: Do you agree that as written, there would be compliance with the provisions of II.B. through II.P. of the proposed plan if the system implemented, as to the particular sub-paragraph, programs or policies or procedures regarding the r:lhom,lr<ndlcyllr><l'dca-jah.ra 3 particular matter addressed in the paragraph. If the answer is negative, please explain the basis for the answer. ANSWER: Yes. INTERROGATORY NO. 6: As the plan is written, would the court have the authority, in the opinion of the LRSD, to hold a system official (s) (sic] in contempt of court for failure to implement a term of a particular policy of the district, which the LRSD views as encompassed by one of the sub-paragraphs in II.B. through II.P. of the plan, but which is not specified in the plan. If your answer is in the affirmative, please explain the basis for the answer. ANSWER: Objection. This interrogatory calls for the legal opinion of counsel for LRSD which is privileged under the attorneyclient privilege. Without waiving this objection, LRSD states that the district court would have authority to enforce the Revised Plan using its contempt power. INTERROGATORY NO. 7: As the plan is written, does any provision of paragraphs II.B. through II.P. of the plan require any action on the part of the LRSD if at a particular school there is substantial racial disparity, atypical in the LRSD system, in the numbers of black students suspended, the numbers of black males placed in special education classes, or the numbers of black students in the gifted and talented program. If the answer is affirmative, please identify the provision(s) which is the basis of the answer. (:\homolfcndlcyllndldoojooh.,.. 4 ANSWER: Paragraphs G., H. and I. of Section II state LRSD's obligations with regard to special education, student discipline and gifted and talented, respectively. Compliance with these paragraphs would require LRSD to investigate a racial disparity which varies substantially from what would be expected. INTERROGATORY NO. 8: Do you maintain that the .LRSD complies, currently, with each obligation set forth in Part II. of the plan. If not, please describe in detail the area(s) of noncompliance. ANSWER: The obligations set forth in Section II encompass the core obligations from LRSD' s current desegregation plan. LRSD maintains that it has substantially complied with its current desegregation plan. INTERROGATORY NO. 9: With respect to II.B. of the proposed plan, please identify as to each category of positions to which it applies, the proportion black in the relevant labor market and the source of this information, and the proportion black of the work force at present. ANSWER: LRSD intends to rely on federal EEOC statistics for Pulaski County, the State of Arkansas and the nation as a whole to determine the percentage of qualified African-Americans in the relevant labor market. With regard to the proportion of AfricanAmerican teachers and administrators, see Exhibits A, B and C attached. LRSD' s noncertified personnel is 73. 8% African-American. INTERROGATORY NO. 10: With respect to II.C. of the proposed plan, please identify as to each category of positions to which it applies, the meaning of the words "the pool of candidates eligible f:lhomolfcndlcyllnd'dc.-jc,oh.1W 5 for promotion", the proportion black in that pool and the source of the information, and the proportion black of the persons employed in the category at present. ANSWER: The "pool of candidates eligible for promotion" includes current employees who satisfy all eligibility requirements imposed by law or by the Board for a position. LRSD objects to identifying every position for which every employee is currently eligible for promotion as unduly burdensome. With regard to the percentage of African-Americans currently employed by LRSD, see Answer to Interrogatory No. 9. INTERROGATORY NO. 11: With respect to II.D. of the proposed plan, please identify the positions covered within the term "certified personnel" and provide as to each category the number of persons currently employed in the LRSD by race. ANSWER: "Certified personnel" are LRSD employees who must possess teaching or administrative certificates issued by the State of Arkansas in order to hold their position. With regard to the percentage of African-Americans currently employed by LRSD, see Answer to Interrogatory No. 9. INTERROGATORY NO. 12: With respect to II.E. of the proposed plan, please identify any category of certified personnel where the LRSD does not have the right to assign personnel for the good of the system and the basis of the limitation. ANSWER: See Articles XV through XVIII of the PN Agreement, attached hereto as Exhibit D, and the Arkansas Teacher Fair Dismissal Act. r:lhomellcndlcyUrld'da-jooh.,a 6 I I I I I I I I I I I I INTERROGATORY NO. 13: With respect to II.H. of the proposed plan, please describe in detail any specific initiative(s) in the LRSD at present, whether involving particular personnel, or standards, designed to guard against black students' receiving discipline for conduct for which white students are not disciplined, black students' receiving discipline for trivial matters, and/or black students' receiving more severe discipline than white students for similar conduct. ANSWER: LRSD expects all of its students, regardless of race or socioeconomic background, to comply with the Student Rights and Responsibilities Handbook. If a student fails to comply, the student will be disciplined as provided in the Handbook. Discipline information including the race of the student, the race of the administrator, the nature of the offense and the sanction imposed is compiled by the schools and maintained by LRSD. LRSD's Associate Superintendent for Student Discipline reviews this information in an attempt to identify possible racial discrimination. INTERROGATORY NO. 14: With respect to II.I. of the proposed plan, please define, with specificity, the word "qualified," as it applies to each of the three areas discussed in the obligation, namely "extracurricular activities", "advanced placement courses", and "gifted and talented" programs. ANSWER: The phrase "qualified African-American students" means African-American students who satisfy the eligibility criteria for an activity or program. For many activities and (:\hoorcll'endlcyll..dldoo-jolh.ra 7 programs, there are eligibility criteria other than student interest. INTERROGATORY NO. 15: With respect to II.J. of the proposed plan, does LRSD agree that as written the system would be in compliance with this provision if the system continued to implement any two programs with its federal Title I monies to improve the academic achievement of African-American students. If not, lease (sic) explain the basis for the disagreement. ANSWER: No. LRSD must also implement the programs, policies and/or procedures set forth in Section V of the Revised Plan. INTERROGATORY NO. 16: With respect to II.L. of the proposed plan, please define the terms "equitable allocation," "technological resources," and "educational resources." Also, please identify any data source allowing a determination of whether these resources are equitably allocated to LRSD schools at present. ANSWER: The phrase "equitable allocation" means to allocate based on need and without bias or favoritism. The term "technological resources" means up-to-date computer and information technology. The term "educational resources'' includes teachers, teacher aides, equipment and supplies. With regard to a data source for determing whether these resources are currently equitably allocated, see the technology work team report, the individual school profiles and the LRSD budget. INTERROGATORY NO. 17: With respect to II.M. of the proposed plan, please define the term "equitable" and identify the matters encompassed in the terms "maintenance and repair." In addition, /:lhomo,1/crdlcylltod'doo-jch.,.. 8 please identify any source of data available to ascertain compliance with this obligation on a school-by-school basis. ANSWER: The term "equitable" means based on need and without bias or favoritism. The terms "maintenance and repair" include the routine upkeep of the building and grounds and the repair or replacement of elements of the building and grounds which are no longer functional. LRSD maintains records which would indicate maintenance requests submitted by schools, the priority assigned to those requests and when and if those requests were acted upon. INTERROGATORY NO. 18: With respect to II.N. of the proposed plan, please identify any specific initiatives currently undertaken in the LRSD to ascertain whether or not guidance or counseling services provided to African-American students involve steering to a restricted range of courses and/or postsecondary educational opportunities. ANSWER: LRSD recognizes that African-American students are underrepresented in upper-level courses and has implemented strategies to address that issue. Specifically with regard to guidance and counseling services, LRSD has requested a National Science Foundation grant to fund training modeled after TESA and EQUALS to assist counselors in motivating African-American students to take the courses necessary to later be successful in upper-level science and math courses. INTERROGATORY NO. 19: With respect to II.O. of the proposed plan, does LRSD maintain that this subparagraph adds anything to r:""'-lfcndley~r,d\deo-jcoh.ra 9 other obligations of the plan. If so, please describe with specificity what it adds. ANSWER: Yes. The obligations in Section II should be interpreted consistent with Paragraph 0. INTERROGATORY NO. 20: With respect to II. P. of the proposed plan, please set forth the number of persons the LRSD plans to assign on a full-time basis to compliance/monitoring activities and the categories of positions to be staffed. In addition, please describe any steps to insure that the make-up of the staff includes a substantial number of African-American persons and any role which LRSD is willing to give the representative of the Joshua Intervenors in the selection of this staff. ANSWER: These decisions have not yet been made. INTERROGATORY NO. 21: With respect to III. A. 1. of the proposed plan, please identify any document and any existing analysis stored in any other manner projecting school make-up by race if the steps described in this subparagraph are implemented. If any such data does not currently exist, please describe how such a projection could be done with data and resources available to the LRSD. ANSWER: LRSD is currently working with Edulog software to project school make-up under scenarios consistent with Section III of the Revised Plan. INTERROGATORY NO. 22: With respect to III.B. I . -5 of the proposed plan, please: (i) identify all written standards governing these transfers and (ii) describe any unwritten practices governing l:ll,anollcndlcy\Jnd'du-jooh.,a 10 one or more of these transfers. (iii) In addition, please define the concepts of "capacity limitations" and "reasonable requirement" identifying any designations of schools capacities to be utilized. (iv) In addition, please explain the language "a special need arising out of circumstances unique to a particular student" by reference to the circumstances of youth receiving such transfers in 1997-98 and explain who does and who would decide that the requisite circumstances exist. (v) Lastly, please identify the numbers of students by race utilizing each category of such transfers in 1997-98. ANSWER: (i) No additional standards have been developed beyond what is contain in the Revised Plan. (ii) None. (iii) A school's capacity is a function of the physical plant and the educational programs being implemented at a school . At this time, LRSD is using the school capacity numbers attached hereto as Exhibit E. The "reasonable requirements" described in subparagraphs 1 through 5 of Section III.B. relate to procedural requirements which may be imposed by LRSD to ensure that student assignment occurs in a timely and efficient manner. (iv) Special circumstances transfers as described by the Revised Plan are currently handled through an appeals committee composed of five members with individual members selected by the LRSD Board of Directors, the Biracial Committee, the PTA Council r:lhomo\fendlcyUnod'dc.-jooh.,a 11 and the Little Rock CTA. The committee reviews requests for transfers based on geographic isolation, racial isolation, medical hardship and other extenuating circumstances. This committee was established by the Tri-District plan and has been continued by LRSD under its current plan. (v) Records concerning transfers will be made available upon request at a time and date mutually agreed to by counsel. INTERROGATORY NO. 23: With respect to III. E. of the proposed plan, please identify any potential sites for the school in west Little Rock, including any sites set forth in any study. In addition, please state whether the LRSD envisions the court's approving the site prior to its final approval. ANSWER: No potential site has been identified. Although LRSD anticipates keeping both the court and the parties informed about the site selection process, the site would not have to be approved by the court except as provided in Section IX.B. of the Revised Plan. INTERROGATORY NO. 24: With respect to IV.E. of the proposed plan, please describe any existing agreements, standards, and practices relating to cooperative efforts of the LRSD and PCSSD. ANSWER: See Interdistrict Desegregation Plan. INTERROGATORY NO. 25: With respect to V.B. and C. of the proposed plan, please (i) identify the author or authors of the provisions, committees and entities, designating the provision or provisions associated with each such author; ( ii) identify any document(s) providing further explanation of any provision(s) of f:lhomo\fcndlcyllrod\doo-jooh.,_ 12 the proposal; (iii) regarding parts B.l.a., B.2.a., and B.3.a., please identify any standards describing the level of competency envisioned in each instance and how it would be assessed; is developing the standards and the general timelines for that effort; and (iv) regarding these three parts of the plan, please state whether LRSD plans to have students satisfy a test requirement prior to moving to the next grade; if the matter is not decided, but such a requirement remains an option, please indicate. ANSWER: See curriculum work team report. INTERROGATORY NO. 26: With respect to V.C.4. of the proposed plan, what is the reason for evaluating Algebra I placement procedures and what would be done with the evaluation results. ANSWER: See curriculum work team report. INTERROGATORY NO. 27: With respect to V.D. of the proposed plan, please identify any standards for use of the "additional funding." If none currently exist, how would standards be developed and in what time period. Lastly, what is the position of the LRSD regarding the use of some funds to pay area college students to tutor in these schools, during and outside the regular school day, on a one-to-one basis. ANSWER: See incentive school work team report and incentive school individual school plans. LRSD has not taken a position on the use of some funds to pay area college students to tutor in the incentive schools. INTERROGATORY NO. 28 : With respect to V.F. of the proposed plan, please identify any standards for this effort and provide a (:lhonwlfcrdlcyUtwd'-"jcoh.- 13 definition of the language "parental and community relations linkage system." ANSWER: See community links work team report. INTERROGATORY NO. 29: With respect to V.I. of the proposed plan, please explain why the title and the first paragraph apply to teachers and the next two paragraphs apply to certified personnel. As to V.B., what person or persons would decide when the desegregative impact would be outweighed. ANSWER: All of Section VI applies to certified personnel. The superintendent or his designee would decide when the desegregative impact would be outweighed by the educational benefit from allowing a teacher to remain in his or her present assignment or to transfer to another assignment. INTERROGATORY NO. 3 0: With respect to Part VII. of the proposed plan, please identify all documents alluded to in this part, including but not limited to "compliance standards and procedures", and/or further explanatory of the meaning of this part. ANSWER: The compliance standards and procedures have not yet been developed. Section VII is based on the requirements for an effective corporate integrity program under the Federal Sentencing Guidelines 8Al.2. INTERROGATORY NO. 31: What if any impact would the court's approval of the proposed plan, or a modified version, have on the life of the agreement which LRSD maintains was made regarding fee payments to counsel for the Joshua Intervenors after the payment of (:lhomo\lcrdlcyllnd'da,-jo,11.,_ 14 the amount described in the Settlement Agreement. If the LRSD view is that the agreement would continue in force, please set forth the terms of the agreement on which LRSD relies and explain how the agreement could continue in view of the terms of the agreement asserted by the LRSD. ANSWER: The fee agreement was part of the settlement agreement which is not being modified by the Revised Plan. REQUEST FOR PRODUCTION NO. 1: Please provide a copy of each document which you have identified in responding to interrogatories numbered 2 through 30. RESPONSE: LRSD will make the documents identified herein available for inspection upon request at a time and date mutually agreed to by counsel. INTERROGATORY NO. 32: Do you consider these interrogatories and req~est for documents as continuing and agree to supplement your answers as required by the Court's order of October 23, 1997? ANSWER: LRSD will comply with the Federal Rules of Civil Procedure and the orders of the district court. r:\homolfc..dlcy\lr,d\dao-_jool,.ra 15 VERIFICATION STATE OF ARKANSAS) ) ss. COUNTY OF PULASKI) I, Dr. Leslie V. Carnine, state under oath that I am the Superintendent of the Little Rock School District, that the foregoing answers have been prepared from information gathered from personnel and records of the District, that the information provided herein is true and correct to the best of my knowledge and belief, and that I am authorized to execute this document on behalf of the District. LITTLE ROCK SCHOOL DISTRICT BY:~ DR. LESIEV.CARNINE SUBSCRIBED AND SWORN TO before me, a notary public, on this day of December, 1997. r:lhomolfcndl,:yllnodldco-jooh.,.. Christopher J. Heller John C. Fendley, Jr. FRIDAY, ELDREDGE & CLARK 2000 First Commercial Building 400 West Capitol Avenue Little Rock, Arkansas 72201-3493 Attorneys for Plaintiff, Little Rock School District BY: 16 CERTIFICATE OF SERVICE I certify that a copy of the foregoing has been served on the following people by depositing a copy of same in the United States mail on this 3rd day of December, 1997. Mr. John W. Walker JOHN W. WALKER, P.A. 1723 Broadway Little Rock, AR 72201 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. 425 W. Capitol, Suite 3400 Little Rock, AR 72201-3472 Mr. Richard Roachell Mr. Travis Creed Roachell Law Firm First Federal Plaza 401 West Capitol, Suite 504 ~ittle 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 f:'llornolfcndlcyUl'ICl'da-jooll.,.. 17 Elementary Teachers - 1993 , 17 i . 4 t---15--- --25.o ---- -- -1L2% - 18.2% -18.0% 3 Total ---  246 r 434  ...  i .f i IC PLAINTIFF'S EXHIBIT A Elementary Teachers - 1994 --- -- 18 - --- -- --- . 17 191)% -L5.3% . '---- --  61 . 5 % - -27. 2% - ' 0 Elementary Teachers - 1995 -,_,-----+--.,.,----+---- --------- ------ -- . 0 . 0 Elementary Teachers - 1996 I I ;- -r-- -- 56.3% -- ....... 22. I%- 2 12 4 Elementary Teachers - 1997 3 - -  9 r6   60. o -1 24.2 - 12 : \  -- 2r- - 46.2% - --1 OA% - Elementary Teachers - 1998 i ! 3 ........... - 51.3% - .. 15.5% -- Secondary Teachers -1993 ALTLRN 4 2 66.7% CENTRAL 21 49 30.0% CLOVERDALE 2 30 6.3% DUNBAR 8 23 25.8% FAIR 7 29 19.4% FOREST HEIGHTS 9 20 31.0% HALL 9 35 20.5% HENDERSON 9 26 25.7% MABELVALE 3 20 13.0% MANNM/S 13 22 37.1% MCCLELLAN 12 24 33.3% PARK.VIEW 9 28 24.3% PULASKI HEIGHTS 4 28 12.5% SOUTHWEST 15 15 50.0% 93 Total 125 351 26.3% Secondary Teachers - 1994 ALTLRN 4 2 66.7% CENTRAL 25 48 34.2% CLOVERDALE 5 30 14.3% DUNBAR 8 25 24.2% FAIR 8 28 22.2% FOREST HEIGHTS 9 19 32.1% HALL 10 34 22.7% HENDERSON 8 30 21.1% MABELVALE 6 21 22.2% MANNM/S 13 25 34.2% MCCLELLAN 12 27 30.8% PARKVIEW 11 28 28.2% PULASKI HEIGHTS 4 29 12.1% SOUTHWEST 15 15 50.0% 94 Total 138 361 27.6% 40.4% 3.7% -20.0% -.5% -6.8% 4.8% -5.8% -.5% -13.2% 10.9% 7.1% -1.9% -13.8% 23.7% er;- -~=~ ... ;J~mlg,&;? ',~zj~g,~~ 39.0% 6.6% -13.4% -3.4% -5.4% 4.5% -4.9% -6.6% -5.4% 6.6% 3.1% .5% -15.5% 22.3% PLAINTIFF'S 1 EXHIBIT s :5 J Secondary Teachers - 1995 Scn"o' ~~- '~-~ . - ,._, . ::;;:. , . ..  - .. ---: -  ...,  - ~~ 1:eme.." r:i-,i ..~... ~ ~ n,_i.c,..a, .i ,,f~ :-.-:..:.P.. ~e,rc" ent,a_.g e , ' . . -  , ~- , . . . ~.  .-~-- -.: -~:~1:-.-- : .r.:. :':"'=:" -.::-  .. :- ! .. -  . ~  . ;- -}~- ;..,,f.,.   _; ,  ~ capj ~ ;~~~~~c.AA,:;::,.:~ ~:...: Y.anance ;. ALTLRN 4 2 66.7% 36.0% CENTRAL 24 42 36.4% 5.7% CLOVERDALE 5 24 17.2% -13.4% DUNBAR 10 20 33.3% 2.6% FAIR 13 23 36.1% 5.4% FOREST HEIGHTS 12 19 38.7% 8.0% HALL 10 34 22.7% -8.0% HENDERSON 10 26 27.8% -2.9% MABELVALE 5 21 19.2% -11.5% MANNM/S 10 26 27.8% -2.9% MCCLELLAN 12 24 33.3% 2.6% PARK.VIEW 10 28 26.3% -4.4% PULASKI HEIGHTS 7 29 19.4% -11.2% SOUIBWEST 15 14 51.7% 21.0% 95 Total 147 332 30.7% Secondary Teachers - 1996 s~il~l~l~fillE1~ ~JH~tt~~,r.:i ~~~pt~~!~: ALT LRN ' 4 2 66.7% 33.1% CENTRAL 23 41 35.9% 2.4% CLOVERDALE 11 20 35.5% 2.0% DUNBAR 15 18 45.5% 11.9% FAIR 15 25 37.5% 4.0% FOREST HEIGHTS 12 20 37.5% 4.0% HALL 10 36 21.7% -11.8% HENDERSON 19 20 48.7% 15.2% MABELVALE 5 22 18.5% -15.0% MANNM/S 12 25 32.4% -1.1% MCCLELLAN 10 32 23.8% -9.7% PARK.VIEW 12 29 29.3% -4.3% PULASKI HEIGHTS 6 32 15.8% -17.7% SOUTHWEST 15 13 53.6% 20.0% 96 Total 169 335 33 .5% Secondary Teachers - 1997  ~=ifl ~"I- m11me'rc'efiliifff ' ..- .. ~Rercenta e, . CENTRAL 24 44 35.3% .4% CLOVERDALE 12 19 38.7% 3.8% DUNBAR 14 21 40.0% 5.1% FAIR 14 20 41.2% 6.3% FOREST HEIGHTS 11 18 37.9% 3.1% HALL 11 33 25.0% -9.9% HEDERSON 17 19 47.2% 12.4% MABELVALE 5 20 20.0% -14.9% MANNM/S 12 25 32.4% -2.4% MCCLELLAN 13 30 30.2% -4.6% PARK.VIEW 14 28 33.3% -1.5% PULASKI HEIGHTS 4 35 10.3% -24.6% SOUTHWEST 19 10 65.5% 30.6% 97 Total 174 325 34.9% Secondary Teachers - 1998 . :.:f.i~:~~~~17:(f-;~.;BpiJ .~ --~~:n . caira ' ~- ' ~caw an"'---.; ~ercefftre.~canl ~ :r.ercen~ge.:. ' Sclioolf:f:~,:t~".. .~ _,; , aniei ~~-~ ~ :.,.-.:~} ~:~~,~J.;: ~- ; --:~~4t.lm.;i -~-~~~- i~~~.~ ;:i;. ~3:~e;;, ALTLRN ' 2 5 28.6% -7.4% CENTRAL 27 48 36:0% .0% CLOVERDALE 13 19 40.6% 4.6% DUNBAR 17 22 43 .6% 7.6% FAIR 11 23 32.4% -3 .6% FOREST HEIGHTS 14 17 45 .2% 9.2% HALL 11 33 25.0% -11.0% HENDERSON 16 19 45 .7% 9.7% MABELVALE 4 21 16.0% -20.0% MANN MIS 15 23 39.5% 3.5% MCCLELLAN 14 29 32.6% -3.4% PARK.VIEW 16 29 35.6% -.4% PULASKI HEIGHTS 6 31 16.2% -19.8% SOUTHWEST 19 10 65.5% 29.5% 98 Total 185 329 36.0% Central Office Administrators - 1993 Superintendent 0 Assistant Superintendent 4 2 Departmental Directors 5 12 93 Total 9 15 Central Office Administrators - 1994 Superintendent 0 Assistant Superintendent 3 2 Departmental Directors 5 13 94 Total 9 IS Central Office Administrators - 1995 Superintendent 0 Assistant Superintendent 3 3 Departmental Directors 6 14 95 Total 10 17 Central Office Administrators - 1996 Superintendent 0 Assistant Superintendent 2 3 Departm,ental Directors 5 13 96 Total 8 16 Central Office Administrators - 1997 Superintendent 0 Assistant Superintendent 2 2 Departmental Directors 4 12 97 Total 6 IS 0.0% 66.7% 29.4% 37.5% 100.0% 60.0% 27.8% 37.5% 100.0% 50.0% 30.0% 37.0% 100.0% 40.0% 27.8% 33.3% 0.0% 50.0% 25.0% 28.6% ~ PLAINTIFF'S EXHIBIT c,., Central Office Administrators - 1998 Superintendent 0 2 0.0% Assistant Superintendent 2 2 50.0% Departmental Directors 4 10 28.6% 98 Total 6 14 30.0% Principals and Assistant Prlnlclpals -1993 Principals and Assistant Prlnlclpals - 1994 s 8 18 16 52.9% S2 47 S2.So/o Principals and Assistant Priniclpals - 1995 Principals and Assistant Prinlclpals - 1996 r--- -- - ; - :~ . ~:.::-,..1- 11: -11 -~\:::;:t~: ~~ l~-;''._~::'.i~~i~~;:f.:i!: l L-.ac ~ :-~--~t~(_I~ . - - ~r ~'l.,.t.~~l:~:..!! Elementarv Princioals 17 18 48.6% Elementary Assistant Principals II s 68.8% Secondary Principals 8 6 57.1 o/o Secondary Assistant Principals 20 13 60.6% 96 Total S6 42 53.1 o/o Principals and Assistant Prinicipals - 1997 Secondary Ass 20 16 55.6% 97 Total 57 44 56.4% Principals and Assistant Priniclpals - 1998 11 5 s 9 5 64.3% s 20 16 55 .6% - 98 Total S6 4S 55.4% ARTICLE XV TEACHING ASSIGNMENTS A. The procedure outlined below shall be followed in making teaching assignments: 1. Teaching assignments shall be based upon training, experience, competence, seniority, tenure, and such other factors as would indicate success in the position to be filled. 2. To assure that students are taught by teachers working within their areas of competence, teachers shall not be assigned, except temporarily and for good cause, outside the scope of their teaching certificates of their major or minor field of study. Teachers assigned outside their major or minor fields shall not be penalized on the salary schedule in any way. When requested, the Director of Personnel will make available to the Association a list of teachers assigned outside their major or minor fields.  3. All teaching assignments will be made by the principal or his/her superiors after the following steps are taken: a. Each year all teachers will submit in writing their personal preference for grade level, group and subject assignments, and such preference shall be a factor in making assignments. b. Department Coordinators will be consulted before assignments are made in their departments. 4. Secondary teachers shall not be required to teach more than two (2) subject matter areas with no more than two (2) preparations involved. Basic, regular, and enriched classes shall be considered separate preparations. Exceptions will only be made when it would otherwise be impossible to enroll all students who have registered for a required course. Teachers assigned more than two (2) preparations will be so notified as soon as possible and in no case later than three (3) weeks before the teach ing assignment is to commence. No teacher shall be assigned more than three (3) preparations under any circumstances. 5. Schedules of teachers who are assigned to more than one (I) school shall be arranged so that such teachers shall not be required to engage in an unreasonable amount of interschool travel. 6. The principal shall or should consult with the Building Coordinating Committee in regard to the tentative master schedule for the following year, and all teachers will be given an opportunity to discuss their tentative assignments with the principal if they so request. B. The following procedure shall be used for notifying teachers of their assignments: 1. Returning teachers shall be given written notice of their tentative grade levei, grouping, subject area assignments, building assignments, and room assignments by the end of the current school year. Newly elected teachers shall be given such notic