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 v. PULASKI COUNTY SPECIAL SCHOOL DISTRICT NO. 1, ET AL MRS. LORENE JOSHUA, ET AL KATHERINE KNIGHT, ET AL INTERROGATORIES AND REQUESTS FOR PRODUCTION TO THE JOSHUA INTERVENORS PLAINTIFF DEFENDANTS INTERVENORS INTERVENORS Plaintiff Little Rock School District ("LRSD") submits the following Interrogatories and Requests for Production to the Joshua Intervenors ("Joshua") in accordance with Fed. R. Civ. P. - 33 and 34: GENERAL DEFINITIONS AND INSTRUCTIONS (A) "you" or "your" Shall mean Joshua or any person acting on Joshua's behalf; (B) "person" Shall mean any individual, corporation, partnership, joint venture, firm, associaiion, proprietorship, agency, board, authority, commission, and other such entities; (C} "communicate" or "communication" Shall mean every manner or means of disclosure, transfer or exchange, and every disclosure, transfer or exchange of f:\homolfendlcy~rod-jooh.m. information whether orally or by document or whether face to face, by telephone, mail, personal delivery, or otherwise; (D) "document" Shall mean any original written, typewritten, handwritten, printed or recorded material, as well as all tapes, disks, non-duplicate copies and transcripts thereof, now or at any time in your possession, custody or control; and, without limiting the generality of the foregoing definition, but for the purposes of illustration only, "document" includes notes, correspondence, memoranda, business records, diaries, calendars, address and telephone records, photographs, tape recordings, financial statements and records. Without limitation of the term "control" as used in the preceding sentence, a document is deemed to be in your control if you have the right to secure the document or a copy thereof from another person or a public or private entity having actual possession thereof. If a document that is responsive to a request for identification or production is in your control, but is not in your possession or custody, identify the person with possession or custody. If any document that is responsive to a request for identification or production was, but is no longer, in your possession or subject to your control, state what disposition was made of it, by whom, and the date or dates or approximate date or dates on which disposition was made, and why; f:\homolfcnd l.:yU ...ildoo-jcoh..- 2 (E) "identify" (i) As to a person (as defined), shall mean the persons name, business and residence address(es); and, if not an individual, state the type of entity and the address of its principal place of business; (ii) As to a document, shall mean the type of document (letter, memo, etc.) the identity of the author or originator, the date authored or originated, the identity of each person to whom the original or copy was addressed or delivered, the identity of such person known or reasonably believed by you to have present possession, custody, or control thereof, and a brief description of the subject matter thereof, all with sufficient particularity to request its production under Rule 34 of the Federal Rules of Civil Procedure; (iii) As to a communication, shall mean the date of the communication, the type of communication (telephone conversation, meeting, etc.), the place where the communication took place, the identity of the person who made the communication, the identity of each person who received the communication, and of each person present when it was made and the subject matter discussed; (F) "Pertaining to" Shall mean constituting, embodying, arising out of, incident to, referring to, mentioned, bearing upon, reflecting, evidencing, affecting, concerning, providing evidence for, or relating to the transaction, individual, entity, act, object, 3 conference, contention, communication, allegation or activity identified; (G) To "describe in detail" Shall mean to provide with respect to any act, occurrence, transaction, event, statement, communication or conduct (hereinafter collectively, "act") all facts pertaining to any such act known to the person answering after due inquiry, including but not limited to a description of each act, the d~te, the location, and the identify of each person involved; (H) "or" shall be construed either conjunctively or disjunctively to bring within the scope of these Interrogatories any information which might otherwise be construed to be outside their scope; (I) "Revised Plan" shall mean LRSD Revised Desegregation - and Education Plan dated September 18, 1997; (J) "current plan" shall mean the LRSD Desegregation Plan dated April 29, 1992; all page and line citations to the current plan shall refer to current plan as set forth in LRSD's "Desegregation Tool Kit," a copy of which is enclosed; (K) "Interdistrict Plan" shall mean the Interdistrict Desegregation Plan dated April 29, 1992; all page and line citations to the Interdistrict Plan shall refer to Interdistrict Plan as set forth in LRSD's "Desegregation Tool Kit," a copy of which is enclosed; The singular includes the plural number, and vice versa. The masculine includes the feminine and neuter genders. The past l:lhomolfcndleyUn,d'dco-jooh.Ull 4 tense includes the presence tense where the clear meaning is not distorted by change of tense. If you do not answer any Interrogatory or Request for Production because of a claim of privilege, set for the privilege claimed, the facts upon which you rely to support the claim of privilege, and identify all documents for which such privilege is claimed. INTERROGATORY NO. 1: Please identify all persons who participated in the preparation of responses to these interrogatories and requests for production of documents . INTERROGATORY NO. 2: Please identify all persons who you intend to call as a lay witness at the hearing on the Revised Plan . INTERROGATORY NO. 3: Please identify all persons who you - intend to call as an expert witness at the hearing on the Revised Plan. REQUEST FOR PRODUCTION NO. 1: Please produce a written report signed by each expert witness identified in your response to Interrogatory No. 3 which contains a complete statement of all opinions to be expressed and the basis and reasons therefor; the data or other information considered by the witness in forming the opinions; any exhibits to be used as a summary of or support for the opinions; the qualifications of the witness, including a list of all publications authored by the witness within the preceding ten years; the compensation to be paid for his testimony; and a listing of any other cases in which the witness f:lhcmo\kndieyUrod\deo-jcoh.w 5 has testified as an expert at trial or by deposition within the preceding four years. ' REQUEST FOR PRODUCTION NO. 2: Please produce all items, th~ngs and documents which you intend to introduce as an exhibit at the hearing on the Revised Plan. INTERROGATORY NO. 4: Do you contend that LRSD is not unitary with regard to student assignments? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 3: Please produce all documents identified in your response to Interrogatory No. 4 above. INTERROGATORY NO. 5: Do you contend that LRSD is not unitary with regard to faculty? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 4: Please produce all documents identified in your response to Interrogatory No. 5 above. INTERROGATORY NO. 6: Do you contend that LRSD is not unitary with regard to staff? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 5: Please produce all documents identified in your response to Interrogatory No. 6 above. INTERROGATORY NO. 7: Do you contend that LRSD is not unitary with regard to transportation? If so, describe in detail f:lhcmo\fcndlcyUnod\doo-joah.inl 6 the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 6: Please produce all documents identified in your response to Interrogatory No. 7 above. INTERROGATORY NO. 8: Do you contend that LRSD is not unitary with regard to extra-curricular activities? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 7: Please produce all documents identified in your response to Interrogatory No. 8 above. INTERROGATORY NO. 9: Do you contend that LRSD is not unitary with regard to facilities? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 8: Please produce all documents identified in your response to Interrogatory No. 9 above. INTERROGATORY NO. 10: Do you contend that LRSD has failed to substantially comply with the Early Childhood Education component (pp. 4-19) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 9: Please produce all documents identified in your response to Interrogatory No. 10 above. INTERROGATORY NO. 11: Do you contend that LRSD has failed to substantially comply with the Special Programs component (pp. 20-27) of the current plan? If so, describe in detail the f:\homolfcrdlcyUr,d\doe-j<>oh ... 7 basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 10: Please produce all documents identified in your response to Interrogatory No. 11 above. INTERROGATORY NO. 12: Do you contend that LRSD has failed to substantially comply with the School Operations component (pp. 28-47) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 11: Please produce all documents identified in your response to Interrogatory No. 12 above. INTERROGATORY NO. 13: Do you contend that LRSD has failed to substantially comply with the Program for Accelerated Learning/Academic Support Programs (pp. 48-57) of the current - plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 12: Please produce all documents identified in your response to Interrogatory No. 13 above. INTERROGATORY NO. 14: Do you contend that LRSD has failed to substantially comply with the Gifted Education component (pp. 58-62) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 13: Please produce all documents identified in your response to Interrogatory No. 14 above. f:lhomolfcndlcyllrod'doo-jooh.u,t 8 INTERROGATORY NO. 15: Do you contend that LRSD has failed to substantially comply with the Multicultural Curriculum component (pp. 63-80) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 14: Please produce all documents identified in your response to Interrogatory No. 15 above. INTERROGATORY NO. 16: Do you contend that LRSD has failed to substantially comply with the Focused Activities component (pp. 81-85) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 15: Please produce all documents identified in your response to Interrogatory No. 16 above. - INTERROGATORY NO. 17: Do you contend that LRSD has failed to substantially comply with the Parkview Science Magnet School component (pp. 86-92) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 16: Please produce all documents identified in your response to Interrogatory No. 17 above. INTERROGATORY NO. 18: Do you contend that LRSD has failed to substantially comply with the McClellan Community School component (pp. 93-94) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. f:\homclfcndleyllnd'dcojooh.mi 9 REQUEST FOR PRODUCTION NO. 17: Please produce all documents identified in your response to Interrogatory No. 18 above. INTERROGATORY NO. 19: Do you contend that LRSD has failed to substantially comply with the Recruitment of Private School students component (p. 95) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO . 18: Please produce all documents identified in your response to Interrogatory No. 19 above. INTERROGATORY NO . 20: Do you contend that LRSD has failed to substantially comply with the Federal Programs component (pp. 96-97) of the current plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 19: Please produce all documents identified in your response to Interrogatory No. 20 above. INTERROGATORY NO. 21: Do you contend that LRSD has failed to substantially comply with the Vocational Education component (pp. 98-99) of the current plan? If so, describe in detail the basis(es) for this contention and i dentify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 20: Please produce all documents identified in your response to Interrogatory No. 21 above. INTERROGATORY NO. 22: Do you contend that LRSD has failed to substantially comply with the Library Media Services component (pp. 106-10) of the current plan? If so, describe in detail the f:\homc\/erdlcyUnd'