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'<bjooh.inl 10 basis(es) for this contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 21: Please produce all documents identified in your response to Interrogatory No. 22 above. INTERROGATORY NO. 23: Do you contend that LRSD has failed to substantially comply with the Special Education component {pp. 111-23) 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. 22: Please produce all documents identified in your response to Interrogatory No. 23 above. INTERROGATORY NO. 24: Do you contend that LRSD has failed to substantially comply with the Staff Development component {pp. 20-27) 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. 23: Please produce all documents identified in your response to Interrogatory No. 24 above. INTERROGATORY NO. 25: Do you contend that LRSD has failed to substantially comply with the Support Services component (pp. 129-30) 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. 24: Please produce all documents identified in your response to Interrogatory No. 25 above. f:lhomo\kmlcyllrodldcojooh.n 11 INTERROGATORY NO. 26: Do you contend that LRSD has failed to substantially comply with the Parent Involvement/Community Linkages component (pp. 131-38) 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. 25: Please produce all documents identified in your response to Interrogatory No. 26 above. INTERROGATORY NO. 27: Do you contend that LRSD has failed to substantially comply with the Student Assignments component (pp. 139-44) 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. 26: Please produce all documents identified in your response to Interrogatory No. 27 above. - INTERROGATORY NO. 28: Do you contend that LRSD has failed to substantially comply with the New Futures For Little Rock component (p. 145) 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. 27: Please produce all documents identified in your response to Interrogatory No. 28 above. INTERROGATORY NO. 29: Do you contend that LRSD has failed to substantially comply with the Facilities component (pp. 146- 148) 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. lc\home\fcndlcyllnodldoejooh.inl 12 REQUEST FOR PRODUCTION NO. 28: Please produce all documents identified in your response to Interrogatory No. 29 above. INTERROGATORY NO. 30: Do you contend that LRSD has failed to substantially comply with the Incentive School Academic Programs and Curriculum Development component (pp. 152-70) 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. 29: Please produce all documents identified in your response to Interrogatory No. 30 above. INTERROGATORY NO. 31: Do you contend that LRSD has failed to substantially comply with the Incentive School Operations component (pp. 171~189} 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. 30: Please produce all documents . identified in your response to Interrogatory No. 31 above. INTERROGATORY NO. 32: Do you contend that LRSD has failed to substantially comply with the Incentive School Staffing component (pp. 190-204) 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. 31: Please produce all documents identified in your response to Interrogatory No. 32 above. INTERROGATORY NO. 33: Do you contend that LRSD has failed to substantially comply with the Incentive School Parent f:\hamolfendleyllradldeo-jooh.w 13 Involvement component (pp. 205-14) 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. 32: Please produce all documents identified in your response to Interrogatory No. 33 above. INTERROGATORY NO. 34: Do you contend that LRSD has failed to substantially comply with the Incentive School Parent Recruitment (pp. 215-23) 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. 33: Please produce all documents identified in your response to Interrogatory No. 34 above. INTERROGATORY NO. 35: Do you contend that LRSD has failed to substantially comply with the Educational Equity Monitoring component (pp. 224-26) 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. 34: Please produce all documents identified in your response to Interrogatory No. 35 above. INTERROGATORY NO. 36: Do you contend that LRSD has failed to substantially comply with the Computerized Transportation System component (pp. 227-29) 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. 35: Please produce all documents identified in your response to Interrogatory No. 36 above. l:\hamollordlcyllrtd\doo-Jo,h.bo 14 INTERROGATORY NO. 37: Do you contend that LRSD has failed to substantially comply with the Introduction component (pp. 1-2) of the Interdistrict 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. 36: Please produce all documents identified in your response to Interrogatory No. 37 above. INTERROGATORY NO. 38: Do you contend that LRSD has failed to substantially comply with the Overview component (pp. 3-7) of the Interdistrict 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. 37: Please produce all documents identified in your response to Interrogatory No. 38 above. - INTERROGATORY NO. 39: Do you contend that LRSD has failed to substantially comply with the student Choices and Options component (pp. 8-12) of the Interdistrict 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. 38: Please produce all documents identified in your response to Interrogatory No. 39 above. INTERROGATORY NO. 40: Do you contend that LRSD has failed to substantially comply with the Summer School component (pp. 13- 20) of the Interdistrict Plan? If so, describe in detail the basis(es) for this contention and identify all facts and documents which support your contention. f:\homclfc.-dlcyUnid'dcojcob.inl 15 REQUEST FOR PRODUCTION NO. 39: Please produce all documents identified in your response to Interrogatory No. 40 above. INTERROGATORY NO. 41: Do you contend that LRSD has failed to substantially comply with the Staff Development component (pp. 21-22) of the Interdistrict 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. 40: Please produce all documents identified in your response to Interrogatory No. 41 above. INTERROGATORY NO. 42: Do you contend that LRSD has failed to substantially comply with the School Operations component (pp. 23-34) of the Interdistrict 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. 41: Please produce all documents identified in your response to Interrogatory No. 42 above. INTERROGATORY NO. 43: Do you contend that LRSD has failed to substantially comply with the Special Education component (pp. 35-53) of the Interdistrict 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. 42: Please produce all documents identified in your response to Interrogatory No. 43 above. INTERROGATORY NO. 44: Do you contend that LRSD has failed to substantially comply with the Guidance and Counseling Program component (pp. 54-55) of the Interdistrict Plan? If so, describe f:lhom<\fcrdlcylll'ld'd.,o-jooh.n 16 in detail the basis(es) for this contention and identify all - facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 43: Please produce all documents identified in your response to Interrogatory No. 44 above. INTERROGATORY NO. 45: Do you contend that LRSD has failed to substantially comply with the Parental Involvement/Community Linkages component (pp. 56-58) of the Interdistrict 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. 44: Please produce all documents identified in your response to Interrogatory No. 45 above. INTERROGATORY NO. 46: Do you contend that LRSD has failed to substantially comply with the Public Relations component (pp. i-2) of the Interdistrict 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. 45: Please produce all documents identified in your response to Interrogatory No. 46 above. INTERROGATORY NO. 47: Do you contend that LRSD has failed to substantially comply with any order of the District Court pertaining to the current plan or Interdistrict Plan? If so, identify the order of the district court, describe in detail the basis(es) for your contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 46: Please produce all documents identified in your response to Interrogatory No. 47 above. r:lhorno1ren:11cy11nw1-.i..-jooh.in 17 INTERROGATORY NO. 48: Please describe .in detail Joshua's monitoring of LRSD during the 1992-93 school year, including the identity of all Joshua monitors, and identify all documents pertaining to such monitoring. REQUEST FOR PRODUCTION NO. 47: Please produce all documents identified in your response to Interrogatory No. 48 above. INTERROGATORY NO. 49: Please describe in detail Joshua's monitoring of LRSD during the 1993-94 school year, including the identity of all Joshua monitors, and identify all documents pertaining to such monitoring. REQUEST FOR PRODUCTION NO. 48: Please produce all documents identified in your response to Interrogatory No. 49 above. INTERROGATORY NO. 50: Please describe in detail Joshua's monitoring of LRSD during the 1994-95 school year, including the identity of all Joshua monitors, and identify all documents pertaining to such monitoring. REQUEST FOR PRODUCTION NO. 49: Please produce all documents identified in your response to Interrogatory No. 50 above. INTERROGATORY NO. 51: Please describe in detail Joshua's monitoring of LRSD during the 1995-96 school year, including the identity of all Joshua monitors, and identify all documents pertaining to such monitoring. REQUEST FOR PRODUCTION NO . . 50: Please produce all documents identified in your response to Interrogatory No. 51 above. INTERROGATORY NO. 52: Please describe in detail Joshua's monitoring of LRSD during the 1996-97 school year, including the f:lhomolfcndloyllndldco-jo,h.in 18 identity of all Joshua monitors, and identify all documents pertaining to such monitoring. REQUEST FOR PRODUCTION NO. 51: Please produce all documents identified in your response to Interrogatory No. 52 above. INTERROGATORY NO. 53: Please describe in detail Joshua's monitoring of LRSD during the 1997-98 school year, including the identity of all Joshua monitors, and identify all documents pertaining to such monitoring. REQUEST FOR PRODUCTION NO. 52: Please produce all documents identified in your response to Interrogatory No. 53 above. INTERROGATORY NO. 54: Please identify all persons not currently employed by LRSD known to you to have personal knowledge of LRSD's failure to comply with any obligation under either the current plan or the Interdistrict Plan. INTERROGATORY NO. 55: Please identify all of your communications with persons currently employed by LRSD pertaining to LRSD's compliance with either the current plan or the Interdistrict Plan. REQUEST FOR PRODUCTION 53: Please produce all documents pertaining to the communications identified in your response to Interrogatory No. 55 above. INTERROGATORY NO. 56: Do you contend that either current or past discrimination by LRSD is a proximate cause of the current racial disparity in academic achievement? If so, describe in detail the basis(es) for your contention and identify all facts and documents which support your contention. f:lhcmclfcndlcyllnd'dcejooh.inl 19 REQUEST FOR PRODUCTION NO. 54: Please produce all documents identified in your response to Interrogatory No. 56 above. INTERROGATORY NO. 57: Do you contend that either current or past discrimination by LRSD is a proximate cause of the current racial disparity in student discipline? If so, describe in detail the basis(es) for your contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 55: Please produce all documents identified in your response to Interrogatory No. 57 above. INTERROGATORY NO. 58: Do you contend that either current or past discrimination by LRSD is a proximate cause of the current racial disparity in special education? If so, describe in detail the basis(es) for your contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 56: Please produce all documents identified in your response to Interrogatory No. 58 above. INTERROGATORY NO. 59: Do you contend that either current or past discrimination by LRSD is a proximate cause of the current racial disparity in the gifted and talented program? If so, describe in detail the basis(es) for your contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO . 57: Please produce all documents identified in your response to Interrogatory No. 59 above . INTERROGATORY NO. 60: Do you contend that either current or past discrimination by LRSD is a proximate cause of the current racial disparity in participation in honors and advanced f:lhome\fc,d loyllrodldco-jcoh.ir< 20 placement courses? If so, describe in detail the basis(es) for your contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 58: Please produce all documents identified in your response to Interrogatory No. 60 above. INTERROGATORY NO. 61: Do you believe that continued implementation of the current plan and the Interdistrict Plan would result in LRSD achieving unitary status? If so, please identify when LRSD would be unitary and describe in detail the basis(es) for your response. If not, please describe in detail why and identify those aspects of school operations which would not be unitary. INTERROGATORY NO. 62: Please identify by page number(s) the components of the current plan and Interdistrict Plan which you believe should be modified , and for each component identified, please: a. describe in detail why you believe the component should be modified; b. identify all facts and documents which support your belief that the component should be modified; c. describe in detail the program, policy or procedure which you believe should be substituted for the component; and, d. identify all facts and documents which support your belief that the program, policy or procedure described inc. above should be substituted for the component . f:lhomclfcndlcyll..d\dco-jooh. in. 21 REQUEST FOR PRODUCTION NO. 59: Please produce all documents identified in your response to Interrogatory No. 62 above. INTERROGATORY NO. 63: Please identify by page number(s) those components of the current plan and Interdistrict Plan which you contend should be continued under the Revised Plan, and with regard to each component identified, please describe in detail the basis(es) for your contention and identify all facts and documents which support your contention. REQUEST FOR PRODUCTION NO. 60: Please produce all documents identified in your response to Interrogatory No. 63 above. INTERROGATORY NO. 64: Do you agree with the recommendations 9on~ained in the Student Assignment Work Team report? If not, please identify each recommendation with which you disagree, describe in detail the basis(es) for your disagreement and identi fy all facts and documents which support your position. REQUEST FOR PRODUCTION NO. 61: Please produce all documents identified in your response to Interrogatory No. 64 above. INTERROGATORY NO. 65: Do you agree with the recommendations contained in the Curriculum Work Team report? If not, please identify each recommendation with which you disagree, describe in detail the basis(es) for your disagreement and identify all facts and documents which support your position. !:\homo\fcndlcy\l..dldco-jooh.inl 22 REQUEST FOR PRODUCTION NO. 62: Please produce all documents identified in your response to Interrogatory No. 65 above. INTERROGATORY NO. 66: Do you agree with the recommendations contained in the Technology Work Team report? If not, please identify each recommendation with which you disagree, describe in detail the basis(es) for your disagreement and identify all facts and documents which support your position. REQUEST FOR PRODUCTION NO. 63: Please produce -all documents identified in your response to Interrogatory No. 66